Agreement status and parties
Template for completion and authorised customer agreement. The processor is Daniel Roberts trading as Jernie, 68 Tyn Y Twr, Baglan, SA12 8YD, jernieiq@hotmail.com. The customer’s legal identity, business address, role and authority appear in its completed electronic customer schedule. Publication alone does not execute this agreement or change an earlier contract. A learner’s privacy acknowledgement is not business DPA acceptance.
The independent assessor or centre prepares its schedule during account setup, reviews the complete DPA and verified Jernie supplier/security/backup schedules, and confirms authority before electronic acceptance. An intermediary processor must have its controller’s authority to appoint Jernie. If service schedules remain unverified, the saved document is a draft and acceptance is unavailable. The accepted snapshot, version, signatory/authority, authenticated account and time are preserved; the business’s copy is available in its Downloads area and Jernie’s copy in private IQ Parent records.
Schedule A: processing and instructions
Subject matter: provision of the agreed AssessIQ account, evidence, communication and assessment-support service. Duration: the service term and authorised return/deletion period. Activities: collection, storage, organisation, retrieval, authorised access, selected AI analysis, export, correction and deletion.
People: learners, assessors, centre staff and people included in authorised evidence. Data: account identifiers, course/criteria records, documents, photographs, video/audio, written accounts, messages, feedback, review decisions, AI requests/outputs and audit records. Sensitive data may be incidental; use requires the controller’s specific documented authority and applicable legal conditions.
The customer/authorised controller sets the purpose, lawful basis, necessary content, user permissions, AI instructions and assessment-record retention requirement. Jernie is separately controller for its own customer administration, security and legal records, as described in the Privacy Policy.
1. Documented instructions
Jernie shall process customer personal data only on the controller’s documented instructions, including for international transfers, unless applicable UK law requires otherwise. In that case Jernie shall inform the customer before processing unless legally prohibited. Jernie shall promptly tell the customer if an instruction appears to infringe applicable data-protection law.
Authorised service configuration, use of enabled features and written instructions form the instruction record, subject to the completed schedules. No permission is granted for unrelated sale, advertising use or model training. If the parties disagree about an instruction, affected processing must be restricted while a lawful course is agreed.
2. Confidentiality and security
Jernie shall ensure that people authorised to process customer data are bound by confidentiality duties and receive only the access needed for the task. Jernie shall implement appropriate technical and organisational measures under Article 32, taking account of risk, available technology, implementation costs and the nature of processing.
Schedule C must record the measures actually in place, including access controls, private storage, secure transport, incident handling, recovery arrangements and testing. No unverified certification, recovery objective or backup assurance forms part of this draft.
3. Sub-processors and changes
Jernie shall not appoint a sub-processor without prior specific or general written authorisation from the controller. The agreed Schedule B lists authorised suppliers. Under general authorisation, Jernie shall give advance notice of an intended addition or replacement and a reasonable opportunity to object on data-protection grounds before the change affects customer data.
Jernie shall impose equivalent applicable Article 28 obligations on each sub-processor by contract and remain responsible to the customer for its sub-processor’s performance of those obligations. The parties shall address a valid objection before the affected change proceeds; if they cannot resolve it, they shall arrange an appropriate restriction or termination of affected processing and return/deletion.
4. International transfers
Restricted transfers shall take place only on documented instructions and with a lawful transfer mechanism, required transfer assessment and any necessary supplementary safeguards. A database region is not proof that all supplier operations, support or AI processing remain there. Schedule B must identify the actual contracting entity, relevant processing/support locations, onward transfers and applicable safeguards.
5. Individual rights and controller assistance
Taking account of the processing and available information, Jernie shall use appropriate measures to assist the controller with access, correction, erasure, restriction, objection and portability requests. It shall refer relevant requests to the authorised customer contact without undue delay and act on lawful instructions rather than independently deciding assessment-record requests.
Jernie shall assist the controller in meeting security, breach notification, DPIA and prior-consultation obligations. If a customer is an intermediary processor, assistance shall support its authorised cooperation with the underlying controller.
6. Personal-data breaches
Jernie shall notify the customer without undue delay after becoming aware of a personal-data breach affecting its data. Available information shall include the nature of the incident, affected people/data and approximate scale where known, likely consequences, containment/remedy and a contact point. Information may be supplied in phases without undue delay.
Jernie shall cooperate with investigation and mitigation. The controller retains its own notification decisions and legal deadlines. The processor’s notice must not wait for a complete investigation or the controller’s regulatory deadline.
7. Return, deletion and copies
At the end of processing Jernie shall, at the controller’s choice, return or delete customer data and delete copies unless applicable law requires storage. The completed schedules record method, scope, timetable, any agreed archive, backup handling, legal exceptions and confirmation. Retained copies remain protected and restricted, with deletion instructions reapplied after restoration.
If an assessor or centre does not continue its free trial, the standard instruction is deletion of trial workspace records/files from active storage after the 30-day download window following the recorded trial end. Required assessment records must be exported first. Converted paid accounts are excluded; an unrenewed trial is not placed in the paid archive.
Paid customers can instruct Jernie to keep a private assessment archive for a standard three calendar years from the event recorded in their completed DPA and archive instruction. The event may be learner certification, completion, paid-account closure or a separately documented controller instruction; it is not assumed to be the signup date. Each archive records the actual event date, retain-until date, requirement and any audit, appeal or legal hold. Longer awarding-body, funding or legal requirements must be recorded before deletion is considered.
An archive is a dated copy of the selected assessment portfolio, including evidence files, assessment reviews, criteria and audit records. It is distinct from the working workspace and from a backup. Creating an archive does not delete its source. The owner dashboard sees archive references and retention status, not learner identities or evidence. Authorised customers can download their own completed archive.
Converted paid workspaces are excluded from trial cleanup. Cancelling renewal is not a deletion instruction. At service exit, record the controller’s choice to return or delete, archive instructions where applicable, export/access arrangements, scope, dates, holds and provider-copy expiry. A three-year due date starts a retention review; it does not override a lawful controller instruction or cause automatic paid deletion. Jernie does not promise indefinite storage or recovery.
8. Information, audits and liability
Jernie shall make available the information necessary to demonstrate compliance with Article 28 and allow and contribute to audits and inspections by the controller or its mandated auditor. Arrangements may reasonably protect other customers, confidentiality and security without defeating audit rights or regulatory powers.
The parties shall maintain applicable records and cooperate with the regulator. Contractual liability provisions apply only so far as lawful and reasonable and do not remove individuals’ statutory rights or a party’s direct obligations under data-protection law.
Schedule B: supplier verification
Current service suppliers identified from deployed code are Supabase (authentication, database and private storage), OpenAI Sites (application hosting), OpenAI API (selected AI analysis) and Resend/configured authentication email services (transactional delivery). Netlify hosts jeiq.co.uk and its forms; Stripe handles payments. Whether each supplier is a sub-processor for the particular customer data depends on the workflow.
Core Supabase region: eu-west-1, Ireland. Before acceptance record each relevant legal entity, services/data shared, locations, processing terms, authorised sub-processors, transfer mechanism and assessment, provider retention, and evidence/date of verification. These facts cannot be established merely by naming the provider.
Schedule C: security, exit and customer acceptance
The completed customer schedule records legal business name/address, authorised signatory and role, controller/processor role and authority, privacy/incident contact, awarding-body/funding retention requirements, the three-year archive start event, AI and sensitive-data instructions. Each actual archive also records its start date, retain-until date, reason and hold status.
The verified Jernie service schedule records the actual supplier entities/contracts, processing/support locations, onward suppliers and transfer safeguards, implemented security, database and evidence-file backup/recovery arrangements, copy expiry, return/deletion method and evidence/limitations. Database backup availability alone is not evidence-file backup coverage. Do not treat these schedules as verified or the DPA as accepted until the records exist.
Jernie contact: Daniel Roberts trading as Jernie, 68 Tyn Y Twr, Baglan, SA12 8YD, jernieiq@hotmail.com. Retain the exact accepted DPA, schedules, acceptance method, signatory/authority and effective date with the business contract. Existing agreements are not backdated, repriced or relabelled by this update.