Data Processing Agreement
Effective Date: 01/01/2024
Last Updated: 21/05/2025
This Data Processing Agreement (the "DPA") constitutes a legally binding agreement between Peetchr SAS ("Peetchr") and the entity ("Customer") on whose behalf Peetchr Processes Personal Data under the Terms and Conditions available at [https://peetchr.ai/tos] (the "Terms").Peetchr and the Customer are hereinafter referred to individually as a "Party" and collectively as the "Parties".This DPA forms an integral part of the Terms and is applicable where Peetchr Processes Customer's Personal Data originating from the European Economic Area ("EEA"), United Kingdom ("UK") and/or Switzerland.
1. DEFINITIONS
Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Terms. In this DPA, the following terms shall have the following meanings:"Data Protection Laws" shall mean (a) the GDPR; (b) in respect of the UK, the GDPR as saved into United Kingdom by virtue of section 3 of the United Kingdom European Union (Withdrawal) Act 2018 ("UK GDPR") and the Data Protection Act, 2019 (together, "UK Data Protection Laws"); (c) the Swiss Federal Data Protection Act and its implementing regulations ("Swiss DPA"); in each case, as may be amended, superseded or replaced.
"GDPR" shall mean the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
"Personal Data" shall mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person forming a part of Customer Data.
"Restricted Transfer" means: (i) where the GDPR applies, a transfer of Personal Data from the EEA to a country outside the EEA which is not subject to an adequacy determination by the European Commission; (ii) where the UK GDPR applies, a transfer of Personal Data from the UK to any other country which is not based on adequacy regulations pursuant to Section 17A of the Data Protection Act 2018; and (iii) where the Swiss DPA applies, a transfer of Personal Data to a country outside of Switzerland which is not included on the list of adequate jurisdictions published by the Swiss Federal Data Protection and Information Commissioner.
"Sensitive Personal Information" shall mean information that relates to an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation. It also includes information about an individual's criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws.
"Standard Contractual Clauses" or "SCCs" means (i) where the GDPR applies, the standard contractual clauses as approved by the European Commission (Implementing Decision (EU) 2021/914 of 04 June 2021) and available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914 ("EU SCCs"); (ii) where the UK GDPR applies, the International Data Transfer Addendum to the EU SCCs issued by the UK Information Commissioner, Version B1.0, in force from 21 March 2022 set forth as Schedule D ("UK SCCs") and (iii) where the Swiss DPA applies, the applicable standard data protection clauses issued, approved or recognized by the Swiss Federal Data Protection and Information Commissioner (the "Swiss SCCs") (in each case, as updated, amended or superseded from time to time)."Controller", "Data Subject", "Personal Data Breach", "Processor" and "Process(ing)" shall have the meaning given to them in the GDPR.2. SCOPE AND RESPONSIBILITIES
2.1. This DPA applies to Processing of Personal Data originating from the UK, EEA and/or Switzerland.
2.2. Peetchr shall Process Personal Data only on the Customer's behalf and at all times only in accordance with this DPA. For the avoidance of doubt, Peetchr shall be the Processor where Customer is the Controller of the Personal Data and where Customer is the Processor, Peetchr shall be the sub-processor of Personal Data.
2.3. Within the scope of the Terms, each Party shall be responsible for complying with its respective obligations as Controller and Processor under Data Protection Laws.
3. TERM AND TERMINATION
3.1. This DPA becomes effective upon the Customer subscribing to the Service(s) by agreeing to the Terms. It shall continue to be in force and effect as long as Peetchr is Processing Personal Data pursuant to the Terms and shall terminate automatically thereafter.
3.2. Where amendments are required to ensure compliance of this DPA or a Schedule with Data Protection Laws, the Parties shall make reasonable efforts to agree on such amendments upon the Customer's request. Where the Parties are unable to agree upon such amendments, either Party may terminate the Terms in accordance with the termination procedure contained therein.
4. PROCESSING INSTRUCTIONS
4.1. Peetchr will Process Personal Data in accordance with the Customer's instructions. This DPA contains the Customer's initial instructions to Peetchr. The Parties agree that the Customer may communicate any change in its initial instructions to Peetchr by way of amendment to this DPA, which shall be signed by the Parties.
4.2. For the avoidance of doubt, any instructions that would lead to Processing outside the scope of this DPA (e.g., because a new Processing purpose is introduced) will require a prior agreement between the Parties and, where applicable, shall be subject to the contract change procedure under the respective agreement.
4.3. Peetchr shall without undue delay inform the Customer in writing if, in its opinion, an instruction infringes Data Protection Laws, and provide a detailed explanation of the reasons for its opinion in writing.
5. DETAILS OF DATA PROCESSING
5.1. Subject matter. The subject matter of the data processing under this DPA is Customer Data and End Customer Data.
5.2. Duration. As between Peetchr and Customer, the duration of the data processing under this DPA is determined by Customer.
5.3. Purpose. The purpose of the data processing under this DPA is the provision of the Services initiated by Customer from time to time.
5.4. Nature of the processing. Create, read, update and delete and such other services as described in the Documentation and initiated by Customer from time to time.
5.5. Categories of data subjects. The data subjects could include Customer's employees, suppliers, and End Customers, particularly job candidates.5.6. Categories of Personal Data. What categories of Customer Personal Data are processed or transferred is determined by Customer. Only data points specified by Customer are transferred from the specified data sources. Such data points are primarily related to job candidates, including:NameContact details (e.g., email address, address, mobile phone number)Educational background and employment historyDate of birthGenderPlace of workEmployee statusName and contact details of supervisorPayment detailsCompetencies (hard skills and soft skills)Information related to culture fit and team fitCandidate evaluations and assessments generated through the ServiceVideo or audio "pitches" submitted by candidatesAny other categories determined by Customer
6. PROCESSOR PERSONNEL
6.1. Peetchr will restrict its personnel from Processing Personal Data without authorization. Peetchr will impose appropriate contractual obligations upon its personnel, including relevant obligations regarding confidentiality, data protection and data security.6.2. Peetchr shall ensure that its personnel engaged in the Processing of Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training on their responsibilities, and have executed written confidentiality agreements. Peetchr shall ensure that such confidentiality obligations survive the termination of the personnel engagement.7.
DISCLOSURE TO THIRD PARTIES; DATA SUBJECTS RIGHTS
7.1. Peetchr will not disclose Personal Data to any government agency, court, or law enforcement except with the Customer's written consent or as necessary to comply with applicable mandatory laws. If Peetchr is obliged to disclose Personal Data to a law enforcement agency, Peetchr agrees to give the Customer reasonable notice of the access request prior to granting such access, to allow the Customer to seek a protective order or other appropriate remedy. If such notice is legally prohibited, Peetchr will take reasonable measures to protect the Personal Data from undue disclosure as if it were Peetchr's own confidential information being requested and shall inform the Customer promptly as soon as possible if and when such legal prohibition ceases to apply.
7.2. In case the Customer receives any request or communication from Data Subjects which relate to the Processing of Personal Data ("Request"), Peetchr shall reasonably provide the Customer with full cooperation, information and assistance ("Assistance") in relation to any such Request where instructed by Customer.
7.3. Where Peetchr receives a Request, it shall (i) not directly respond to such Request, (ii) forward the Request to the Customer within five (5) business days of identifying the Request as being related to the Customer and (iii) provide Assistance according to further instructions from Customer.
8. TECHNICAL AND ORGANIZATIONAL MEASURES
8.1. Peetchr shall implement and maintain appropriate technical and organizational security measures to ensure that Personal Data is Processed according to this DPA, to provide assistance and protect Personal Data against a Personal Data Breach ("TOMs"). Such measures shall include the measures set out in Schedule B.
8.2. Peetchr shall regularly assess and evaluate the effectiveness of the implemented TOMs to ensure the security of the Processing.
9. ASSISTANCE WITH DATA PROTECTION IMPACT ASSESSMENT
9.1. Where a Data Protection Impact Assessment ("DPIA") is required under applicable Data Protection Laws for the Processing of Personal Data, Peetchr shall provide, upon request, to the Customer any information and assistance reasonably required for the DPIA including assistance for any communication with data protection authorities, where required, unless the requested information or assistance is not pertaining to Peetchr's obligations under this DPA.
9.2. The Customer shall pay Peetchr reasonable charges for providing the assistance in Clause 9.1, to the extent that such assistance cannot be reasonably accommodated within the normal provision of the Service(s).
10. INFORMATION RIGHTS AND AUDIT
10.1. Peetchr shall, in accordance with Data Protection Laws, make available to the Customer on request in a timely manner such information as is necessary to demonstrate compliance by Peetchr with its obligations under the Data Protection Laws.
10.2. Peetchr shall, upon reasonable notice, allow for and contribute to audits of its Processing of Personal Data, as well as the TOMs (including data Processing systems, policies, procedures and records), during regular business hours and with minimal interruption to its business operations. Upon Customer's written request at reasonable intervals, Peetchr shall make available to Customer relevant information regarding Peetchr's Processing of Personal Data in the form of Peetchr's most recent third party audits and certifications, which may include audit reports such as SOC 2, to ensure compliance with Peetchr's obligations set out in this DPA. Customer agrees that such third party audits and certifications are sufficient to demonstrate Peetchr's compliance with the obligations set out in this DPA.
10.3. The Customer shall pay Peetchr reasonable costs of allowing or contributing to audits or inspections in accordance with Clause 10.2 where the Customer wishes to conduct more than one audit or inspection every twelve (12) months.
10.4. Peetchr will immediately refer to the Customer any requests received from national data protection authorities that relate to its Processing of Personal Data.
10.5. Peetchr undertakes to reasonably cooperate with the Customer in its dealings with national data protection authorities and with any audit requests received from national data protection authorities.
11. PERSONAL DATA BREACH NOTIFICATION
11.1. In respect of any Personal Data Breach (actual or reasonably suspected), Peetchr shall:a) notify the Customer of a Personal Data Breach involving Peetchr or a subcontractor without undue delay.b) provide reasonable information, cooperation and assistance to the Customer in relation to any action to be taken in response to a Personal Data Breach under Data Protection Laws, including regarding any communication of the Personal Data Breach to Data Subjects and national data protection authorities.
12. USE OF SUB-PROCESSORS
12.1. Peetchr has the Customer's general authorisation for the engagement of third-party sub-processors from an agreed list, as set forth in Schedule A. Peetchr will notify the Customer's account administrator of any intended changes to that list through the appointment or replacement of any sub-processor at least fifteen (15) days in advance. The Customer may object to Peetchr's appointment or replacement of a sub-processor prior to its appointment or replacement, provided such objection is based on reasonable grounds relating to data protection. In such an event, Peetchr will either not appoint or replace the sub-processor or, if this is not possible, Peetchr may suspend or terminate the Service(s) (without prejudice to any fees accrued prior to such suspension or termination).
12.2. Where Peetchr, with the Customer's authorisation, engages a sub-processor, it shall do so only by way of a binding written contract which imposes on the sub-processor essentially the same data protection obligations as the ones imposed on Peetchr under this DPA and in accordance with Art. 28 of the GDPR.
12.3. Where the sub-processor fails to fulfil its data protection obligations under the subcontracting agreement, Peetchr shall remain fully liable to the Customer for the fulfilment of its obligations under this DPA and for the performance of the sub-processor's obligations.
13. INTERNATIONAL DATA TRANSFERS
13.1. The Parties agree that when the transfer of Personal Data from the Customer to Peetchr is a Restricted Transfer and applicable Data Protection Laws require that appropriate safeguards are put in place, such transfer shall be subject to the appropriate Standard Contractual Clauses, which shall be deemed incorporated into and form part of this DPA as follows:
13.1.1. In relation to transfers of Personal Data originating from the EEA and subject to the EU GDPR, the SCCs shall apply, completed as follows:a) Module 2 (Controller to Processor) shall apply where the Customer is a Controller and Peetchr is a Processor. Module 3 (Processor to Processor) shall apply where the Customer is a Processor and Peetchr is a sub-processor;b) in Clause 7, the optional docking clause will apply;c) in Clause 9(a), Option 2 shall apply;d) in Clause 11, the optional language will not apply;e) in Clause 17, Option 1 will apply, and the EU SCCs will be governed by the law of France;f) in Clause 18(b), disputes shall be resolved before the courts of Paris, France;g) Annex I, II and III of the EU SCCs shall be deemed completed with the information set out in Schedule A, B and C to this DPA respectively; and
13.1.2. In relation to transfers of Personal Data originating from Switzerland and subject to the Swiss DPA, the EU SCCs as implemented under sub-paragraph 13.1.1 above will apply with the following modifications and shall constitute the Swiss SCCs:a) references to Regulation (EU) 2016/679; shall be interpreted as references to the Swiss DPA;b) references to specific Articles of Regulation (EU) 2016/679; shall be replaced with the equivalent article or section of the Swiss DPA;c) references to "EU", "Union", "Member State", and "Member State law" shall be replaced with references to "Switzerland" or "Swiss law";d) the term "member state" shall not be interpreted in such a way as to exclude Data Subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (i.e., Switzerland);e) Clause 13(a) and Part C of Annex I are not used and the "competent supervisory" is the Swiss Federal Data Protection Information Commissioner;f) references to the "competent supervisory authority" and "competent courts" shall be replaced with references to the "Swiss Federal Data Protection Information Commissioner" and "applicable courts of Switzerland";g) in Clause 17, the Standard Contractual Clauses shall be governed by the laws of Switzerland; andh) With respect to transfers to which the Swiss DPA applies, Clause 18(b) shall state that disputes shall be resolved before the applicable courts of Switzerland.
13.2. Where the UK GDPR applies, the UK SCCs shall apply to transfers of Personal Data originating in the UK to any other country not recognized by the competent United Kingdom regulatory authority or governmental body for the United Kingdom as providing an adequate level of protection for Personal Data.
13.3. For the purposes of descriptions in the SCCs, the Customer agrees that it is the "data exporter" and Peetchr is the "data importer".
13.4. The Parties agree that if the Standard Contractual Clauses are replaced, amended or no longer recognized as valid under Data Protection Laws, or if a Supervisory Authority and/or Data Protection Law requires the adoption of an alternative transfer solution, the data exporter and data importer will: (i) promptly take such steps requested including putting an alternative transfer mechanism in place to ensure the processing continues to comply with Data Protection Laws; or (ii) cease the transfer of Personal Data and at the data exporter's option, delete or return the Personal Data to the data exporter.
14. DELETION OR RETURN OF PERSONAL DATA
14.1. Upon termination of the Customer's account, Peetchr will delete all Customer Data in accordance with the Data Retention Period set forth in the Terms. This requirement shall not apply to the extent that Peetchr is permitted by applicable law to retain some or all of the Personal Data, in which event Peetchr shall isolate and protect the Personal Data from any further Processing.
15. SUPPORT UNDER ARTICLES 32 TO 36 GDPR
15.1. Peetchr shall provide all necessary support to the Customer to ensure compliance with articles 32 to 36 GDPR, including but not limited to:a) Implementation of appropriate technical and organizational measures to ensure a level of data security appropriate to the risk, including but not limited to measures for pseudonymization and encryption, ensuring confidentiality, integrity, availability, and resilience of processing systems and services.b) Promptly informing the Customer of any personal data breach, providing a detailed account of the breach, and assisting with the notification of such breaches to the supervisory authorities and data subjects, as required.c) Conducting regular tests, assessments, and evaluations of the effectiveness of the technical and organizational measures to ensure processing security.d) Assisting the Customer in ensuring compliance with the obligations pursuant to articles 32 to 36 of the GDPR, taking into account the nature of processing and the information available to Peetchr.e) Supporting the Customer, where necessary, in the preparation and maintenance of a Data Protection Impact Assessment (DPIA) when required by law or when the nature of the processing operations necessitates such an assessment.
16. MISCELLANEOUS
16.1. In case of any conflict, the provisions of this DPA shall take precedence over the Terms or provisions of any other agreement with Peetchr.16.2. No Party shall receive any remuneration for performing its obligations under this DPA except as explicitly set out herein or in another agreement.16.3. Where this DPA requires a "written notice" or "written request", such notice or request can also be communicated per email to the other Party. Notices shall be sent to the contact persons set out in Schedule A.
16.4. Any supplementary agreements or amendments to this DPA must be made in writing and signed by both Parties.
16.5. Should individual provisions of this DPA become void, invalid or non-viable, this shall not affect the validity of the remaining conditions of this DPA.The following Schedules form an integral part of this DPA:
Schedule A: List of Sub-processors
Schedule B: Technical and Organizational Measures
Schedule C: List of Parties under the SCCs
Schedule D: UK SCCs
SCHEDULE A: LIST OF SUB-PROCESSORS
Peetchr currently uses the following Sub-Processors:
Sub-Processor
Service Provided
Server Location
Amazon Web Services
Cloud hosting France
Google Cloud
Cloud Computing Netherlands
Vanta Inc.GDPR compliance United States
SCHEDULE B: TECHNICAL AND ORGANIZATIONAL MEASURES
Peetchr implements and maintains appropriate technical and organizational measures to ensure the security, confidentiality, integrity, and availability of Personal Data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. These measures include, but are not limited to:
1. Pseudonymization and Encryption, Art. 32 para 1 point a GDPR
Stored data is encrypted where appropriate, including any backup copies of the dataPersonal data used for AI training is anonymized before processingEncryption of data in transit and at rest
2. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services, Art. 32 para 1 point b GDPR2.1 Confidentiality
2.1.1. Physical access control
Definition of authorized persons; management and documentation of individual authorizationsRegulation of visitors and external staffMonitoring of all facilities housing IT systemsLogging of physical access
2.1.2 System/Electronic access control
User Authentication by strong authentication methods, including two-factor authenticationSecure transmission of credentials (using TLS)Automatic account lockingSuspending inactive sessionsGuidelines for handling passwords and certificatesDefinition of authorized personsManaging means of authenticationAccess control to infrastructure that is hosted by cloud service providerIn-time revocation of access for people who no longer need access / leave the companyAutomated alerting on illegal attempts of logging systems directly or indirectly connected to personal dataUnique credentials per userUse of jump server to restrict access where adequate
2.1.3 Internal Access Control
Automatic and manual lockingAccess right managementAccess right management including authorization concept, implementation of access restrictions, implementation of the "need-to-know" principle, managing of individual access rights.
2.1.4 Isolation/Separation Control
Network separationSegregation of responsibilities and dutiesDocument procedures and applications for the separation
2.1.5 Job Control
Training and confidentiality agreements for internal staff and external staffInformation security assessment for vendors/partners
2.2. Integrity
2.2.1 Data transmission control
Secure transmission between client and server and to external systems by using industry-standard encryptionSecure network interconnections ensured by Firewalls, anti-virus programs, routinely patching software etc.Logging of transmissions of data from IT system that stores or processes personal data2.2.2 Data input control
Logging authentication and monitored logical system accessLogging of data access including, but not limited to access, modification, entry and deletion of dataDocumentation of data entry rights and partially logging security related entries.
2.3 Availability and Resilience of Processing Systems and Services
Backup ConceptImplementation of transport policiesProtection of stored backup media
3. The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident, Art. 32 para 1 point c GDPR
Continuity planning (Recovery Time Objective)Regular testing of backup and recovery procedures
4. A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing, Art. 32 para 1 point d GDPRTesting of emergency equipmentDocumentation of interfaces and personal data fieldsRegular internal and external security assessments and audits
SCHEDULE C: LIST OF PARTIES UNDER THE SCCsData exporter(s):The data exporter is the entity that has subscribed to the Terms and their contact details are as provided by them while subscribing to the Terms.Signature & Date: By entering into the Terms, data exporter is deemed to have signed these SCCs incorporated herein, including their Annexes, as of the Effective Date of the DPA.
Data importer(s):Name: Peetchr SAS Address: 38 rue des Mathurins, 75008 Paris, France Contact person's name, position and contact details:Name: Raphaël BENICHOUDesignation: CEOContact: dataprivacy@peetchr.com Activities relevant to the data transferred under these Clauses: As specified in Part B of Schedule C Signature & Date: By entering into the Terms, Data Importer is deemed to have signed these SCCs incorporated herein, including their Annexes, as of the Effective Date of the DPA. Role (controller/processor): Processor/sub-processor of data exporter
DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferred
Unless provided otherwise by the data exporter, transferred Personal Data relates to the following categories of Data Subjects: data exporter's current or potential customers, data exporter's potential employees, data exporter's employees, admins or other individuals whose Personal Data is transmitted or made available to the data importer by the data exporter in the course of data exporter's use of Services.
Categories of personal data transferred
The transferred Personal Data concerns the following categories of data: The data exporter determines the categories of Personal Data which could be transferred per the Service(s) as stated in the Terms. Such categories may include the following categories of data: name, designation, phone number, e-mail address, social profiles and associated data, educational and employment history, IP address, and any application-specific data transferred by authorized personnel of the data exporter, as well as candidate evaluations and assessments generated through the Service, and video or audio pitches submitted by candidates.
Sensitive data transferred (if applicable) and applied restrictions or safeguards
No sensitive data transferred. The data exporter shall not disclose (and shall not permit any individual to disclose) any Sensitive Personal Information to the data importer for processing.
The frequency of the transfer
Personal Data is transferred on a continuous basis during the term of the Customer's account.
Nature of the processing
Collection, organisation, structuring, storage, consultation, use, disclosure by transmission or otherwise making available, erasure (whether or not by automated means).
Purpose(s) of the data transfer and further processing
Personal Data is transferred in the course of access and use by the data exporter of the Services so that the data importer may provide, support, maintain and improve the Services, particularly for talent assessment and recruiting purposes.
The period for which the personal data will be retained
Upon termination of the data exporter's account, the data importer will delete all Personal Data in accordance with clause 14 of the DPA.
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
As specified in Schedule A.
COMPETENT SUPERVISORY AUTHORITY
In respect of the SCCs:Module 2: Transfer Controller to Processor
Module 3: Transfer Processor to Processor
Where the Customer is the data exporter, the supervisory authority shall be the competent supervisory authority that has over the Customer in accordance with Clause 13 of the SCCs.
SCHEDULE D: UK SCCs
This UK SCCs shall stand included as an addendum to the EU SCCs set implemented under Clause 13.1.1 of this DPA.
Part 1: Tables
For data transfers from the United Kingdom that are subject to the UK SCCs, the UK SCCs will be deemed entered into (and incorporated into this Data Processing Addendum by this reference) and completed as follows:In Table 1 of the UK SCCs, the Parties' details and key contact information shall be as set forth in Schedule C.In Table 2 of the UK SCCs, information about the version of the Approved EU SCCs, modules and selected clauses which this UK SCC is appended to shall be as set forth in Clauses 13.1 and 13.1.1 of this DPA.In Table 3 of the UK SCCs:Annex 1A: List of Parties: Parties are as set forth in Schedule C.Annex 1B: Description of Transfer: Description of Transfer is as set forth in Schedule C.Annex II: Technical and organisational measures including technical and organisational measures to ensure the security of the data: TOMs are as set forth in Schedule B.Annex III: List of Sub processors: Sub processors are as set forth in Schedule A.In Table 4 of the UK SCCs, both the data importer and the data exporter may end the UK SCCs in accordance with the terms of the UK SCCs.
Part 2: Mandatory Clauses
Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of those Mandatory Clauses.
