Sub-processors
The kinds of companies that help us run LinkSync and may process personal information on behalf of the organisations that use it, and how we tell those organisations before anything changes.
Last updated [date]
In short
- We use as few sub-processors as we can, and only for things we can’t sensibly do ourselves.
- Each one works only on our instructions, under a written contract that protects personal information at least as well as our own Data Processing Agreement.
- Personal information is stored in the UK. Where any processing happens elsewhere, the table says so.
- We give customers at least [30] days’ notice before adding or changing a sub-processor, and they can object.
- None of them may sell the information, use it for advertising, or use it to improve their own services.
1. What a sub-processor is
Organisations that use LinkSync are in charge of their visit records (they are the “controller”). We run LinkSync for them (we are their “processor”). A sub-processor is a company we use that may process that personal information on our behalf, for example to host it.
2. Our sub-processors
We list sub-processors by the service they provide. [Customers receive the named list with their Order, and it is available on request to privacy@linksync.co.uk.]
| Service | What they do | Personal information involved | Where | Company |
|---|---|---|---|---|
| Hosting and storage | Runs the LinkSync service, database, file storage, backups, sign-in and key management | All personal information in LinkSync | The UK | [name] |
| Identity checks | Confirms the person in a face check is live and present, and matches them to their enrolment photo. Only for organisations that switch on face checks. | The live face image, checked and not stored; the enrolment photo; and check results | The UK; one step in the European Economic Area, with nothing stored there | [name] |
| Maps and addresses | Shows maps in the web admin, and helps find and check addresses | Addresses and map positions of places, and visit routes shown on a map | The UK | [name] |
| Email delivery | Sends sign-in codes and invitations by email | Email address, name, and the content of the message | [location] | [name] |
| Text messages [if used] | Sends time-critical reminders by text where an organisation switches this on | Mobile number and the content of the message | [location] | [name] |
Our support and internal business tools do not hold customers’ visit records. [Confirm, or add any support desk or similar tool that does.]
3. How we choose and check them
- We check each company’s security and data protection before we use it, and review it regularly.
- Each has a written contract with us that limits what it can do with the information, requires appropriate security and confidentiality, and requires it to help us meet our duties to customers.
- We prefer providers that keep information in the UK. Where processing happens outside the UK, it is covered by UK adequacy regulations or another safeguard UK law recognises. See Annex 4 of our Data Processing Agreement.
- We remain fully responsible to our customers for what our sub-processors do.
4. Notice of changes
Before a new sub-processor starts processing personal information, or before an existing one starts doing something new with it, we will:
- update this page at least [30] days in advance, with the date the change takes effect;
- email the administrators and data protection lead of every customer at the same time; and
- [let anyone subscribe to updates to this page by emailing privacy@linksync.co.uk].
In an emergency, for example if a provider fails and we must replace it quickly to keep LinkSync running, we may give shorter notice. We will tell customers as soon as we can, and they can still object.
Change history
| Date | Change |
|---|---|
| [date] | First version of this page. |
5. Objecting to a change
A customer can object to a change on reasonable data protection grounds by emailing privacy@linksync.co.uk within the notice period. We will discuss it in good faith and try to find a solution. If we can’t, the customer can end the affected part of the service and receive a refund of any prepaid fees for the rest of the term, as set out in the Data Processing Agreement.
6. Who is not a sub-processor
- Systems a customer connects. If a customer sends its data to its own systems through exports [or, once built, our API and automatic updates sent to its systems], those are the customer’s choice and its responsibility, not our sub-processors.
- App stores and phone makers, which provide the app and the phone, act for themselves under their own terms with the user.
- Our professional advisers, such as lawyers and auditors, who see information only where needed and under duties of confidentiality.