Data Processing Agreement for multiple clients

  • Resolved Mariette

    (@mariette-jackson)


    6 years, 6 months ago

    Hi

    I have built websites for multiple clients. I administer these websites and have installed Wordfence on all of them. Can I check – do I need to sign and return the DPA (once) or does each client need to sign one each?

    I hope the former!

    thanks

Viewing 4 replies - 1 through 4 (of 4 total)

  • This depends on the contractual relationship you assume on these websites.

    – If you’re a co-controller you can sign the DPA on behalf of them.
    (You’re mentioned in the privacy policy as the the controller of the data collection)

    – If you’re a processor then you may add Defiant Inc. as a sub-processor.
    (You’re mentioned in the privacy policy as the processor of the data collection)

    – If you’re neither you would pass this on to your clients respectively.
    (You remain anonymous in the privacy policy, unless identification is required by other things, such as access to private data)

    Thread Starter Mariette

    (@mariette-jackson)

    Thank you. I think the second option would apply.

    In that case, do I need to sign a DPA with Wordfence?

    And if yes, would that be one for DPA or a separate one for each client’s website?

    Sorry for my ignorance.

    Yes, sign the DPA (needs to be signed twice in the document) and send it to [email protected] – After that, you have a legal basis to process personal data on behalf of your clients.

    Thread Starter Mariette

    (@mariette-jackson)

    Great, thank you very much for your help with this.

Viewing 4 replies - 1 through 4 (of 4 total)
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