Services

Contracts & Suppliers

We draft and review the agreements that govern personal data moving between you and your customers and suppliers: data processing agreements, checks on a supplier before it gets access to your data, and transfers of data out of Israel. You can then answer a customer’s questionnaire and work with suppliers without a gap between the contract and reality.

When this usually surfaces

The need for these agreements usually shows up at one of these five moments.

#The eventWhat breaks
1A customer sends a security and privacy questionnaireNo documents are ready, and the answers are written in a hurry
2A European customerA GDPR addendum, a mapping exercise, and whether you need a representative in the EU
3A regulated body updates its security annexWhat exactly you undertook, and what happens when the requirements tighten
4A new supplier asks for access to your dataWhat it will see, where the data will be kept, and what the contract says before you start
5A cloud system outside IsraelWhat allows you to transfer the data to it, and where that is recorded

What gets examined

The review covers four areas, from your agreements with customers to your own suppliers.

  • Your DPAs against reality
    Whether your customer DPAs describe what you actually do.

  • Your suppliers
    Your DPAs with the suppliers that hold data for you, and the risk review the Data Security Regulations require before you engage them.

  • Transfers out of Israel
    Where the data is actually stored and processed, and on what basis it may be transferred.

  • Customer audits
    What you will need to produce when a customer or a regulated body audits you.

Deliverables

At the end you receive agreements and records you can sign and work by.

DeliverableWhat it contains
Data processing agreementsDrafting and negotiation of DPAs with customers and suppliers, in Hebrew and English, including a European customer’s requirements.
Supplier addendumA confidentiality and security addendum for your suppliers, with everything the Data Security Regulations require in the contract.
Supplier registerFor each supplier: what data it receives, where the data sits, which processing terms apply, and when it is checked again.
Transfers abroadThe basis for each transfer out of Israel, the recipient’s written undertaking, and the transfer’s entry in the database definitions document.

How it runs

The work runs in five steps, and the scope is set in writing before it starts.

Initial fit call
A first discussion of the need, scope and priorities.
Scope letter
Deliverables, timetable and terms of engagement, in writing, before work starts.
Collection
A questionnaire and documents, then two to three conversations with the relevant people on your side.
Delivery
The deliverables, then a handover session on the gaps and the order to address them.
Continuation, if you want it
Ongoing support or filling the officer role.
  1. 1. Fit call
  2. 2. Scope letter
  3. 3. Collection
  4. 4. Delivery
  5. 5. Continuation

Questions people ask

Does every supplier with access to our data need a contract?

As a rule, yes. The Data Security Regulations require a risk review before you engage the supplier, and a contract that sets out, among other things, what data the supplier processes and for what purpose, the conditions for using sub-processors, incident reporting, and returning the data at the end. The duty applies at every security level, even when the supplier only accesses the data and does not store it. An engagement with a self-employed individual is not subject to it, but that too is worth putting in a contract.

Is our cloud provider's ISO 27001 certification enough?

No. The standard covers security. A transfer out of Israel needs its own basis and a written undertaking from the recipient, and the transfer is recorded in the database definitions document. In most cases the transfer is allowed, and what is missing is the record.

Discuss fit for the service