Simple client DPA · working template
Instructions, separation and deletion in plain English.
This is the public baseline for OTR client rooms. A signed client agreement controls where it differs and should be reviewed by the parties before paid processing begins.
Purpose
OTR processes contact details, priorities, feedback, outcomes and client-supplied research only to deliver the private intelligence service on the client’s instructions.
Controls
Confidential access, client-separated records, encrypted transport, short sessions, no public indexing and an audit trail for material feedback actions.
Exit
On request or termination, OTR exports or deletes client data within 30 days, except data that must be retained by law; routine backups age out under infrastructure schedules.
Processing commitments
Private facts do not become shared facts.
- No foundation-model training with client data.
- No cross-client learning or disclosure.
- Subprocessors are limited to the site, database and necessary service infrastructure.
- Personnel with access are bound to confidentiality.
- A security incident is contained, documented, assessed and communicated without unreasonable delay.
- The client may request access, export, correction, restriction or deletion.
- Client preference may affect relevance only; it cannot change public evidence or source quality.
Controller/processor roles, governing law, subprocessor list and commercial terms must be completed in the signed agreement.