Data Processing Agreement — Draft

CONTRACT DRAFT — not effective until completed, reviewed and agreed by both parties. This page is informational and is not a signed agreement.

Parties: Ride on Railways Ltd (service provider) and [Railway organisation's full legal name and address].

1. Roles and scope

Where the railway organisation determines the purposes and means of processing its user, inspection and incident records, it is expected to act as controller and Ride on Railways Ltd as processor. The parties must confirm the actual allocation of responsibilities; Ride on Railways Ltd may separately be controller for its own account administration and business records.

2. Processing details — Schedule A (to complete)

Subject matter: hosting and administration of the RailStock rolling stock register. Duration: [contract term and exit period]. Nature and purpose: storage, access, retrieval, maintenance, support and authorised communications. Data subjects: [railway staff, members, inspectors, reporters, persons named in incidents and others as applicable]. Data types: [names, contact details, access records, inspections, incident details, photos and any special-category information where applicable].

3. Processor commitments — for legal review

The final agreement must set out documented instructions, confidentiality, appropriate technical and organisational security, rules for subprocessors, assistance with individual rights and security incidents, deletion or return of data at contract end, and information needed to demonstrate compliance including audit arrangements, as applicable under Article 28 UK GDPR.

4. Subprocessors and international transfers — Schedule B

To complete: hosting and email suppliers, locations, subprocessors, transfer mechanisms, notice of changes and objections.

5. Security and incidents — Schedule C

To complete: access controls, encryption, backups, retention, breach notification procedure and timing, recovery, support access and deletion arrangements.

6. Return and deletion of records

Before deletion, an authorised railway administrator may request a ZIP copy of the organisation's records. The export is currently request-based; no automated export is yet available. The parties must agree secure delivery, verification of authority, backup handling and exceptions to deletion.

7. Agreement

Railway organisation: [name / authorised signatory / date]

Ride on Railways Ltd: [authorised signatory / date]