Sinew data processing agreement

UK GDPR Article 28 (and EU GDPR where it applies). Forms part of the Sinew terms of service.

Parties: the agency that installs Sinew (Controller) and PJM Apps Ltd (Processor).

1. Scope

ItemDetail
Subject matterProviding Sinew: client health scoring, alerts, digests, call summaries and briefs
DurationWhile Sinew is installed, plus the 30-day deletion period
Nature of processingReading activity from the Controller's HighLevel sub-accounts; calculating daily totals and scores; storing them; generating AI summaries and briefs; sending emails the Controller sets up
PurposeHelping the Controller keep its clients, as the Controller instructs through Sinew's settings
Data subjectsThe Controller's staff; the Controller's clients' staff (contact names in the Controller's own CRM, people on recorded calls); the Controller's clients' leads and customers, only transiently
Personal data storedAgency staff names, IDs, roles and chosen alert emails; client contact IDs and names in the Controller's own CRM; call summaries (without patient names or health details)
Personal data processed but not storedLead and customer contact records, message metadata and appointment metadata (read in memory, reduced to daily counts, then discarded); call transcripts (held encrypted only until summarised, and never more than 24 hours)
Special category dataNot stored. A call transcript may incidentally contain health information about a patient; patterned identifiers (emails, phone and ID numbers, dates of birth) are removed before it is sent to Anthropic, it is processed only to produce a summary that excludes health details, then deleted

2. Processor obligations

The Processor will:

  1. Process personal data only on the Controller's documented instructions (these terms, the settings the Controller chooses in Sinew, and written instructions), and tell the Controller if it believes an instruction breaks data protection law.
  2. Ensure everyone processing the data is bound by confidentiality.
  3. Apply the security measures in Annex A.
  4. Use sub-processors only as in Section 3.
  5. Help the Controller answer data subject requests and meet its obligations on security, breach notification, impact assessments and prior consultation, taking into account what the Processor can see.
  6. Notify the Controller without undue delay and within 48 hours of becoming aware of a personal data breach affecting the Controller's data, with the information then available.
  7. On uninstall or termination, delete the Controller's data within 30 days, and confirm on request. Daily backups are kept for 7 days, so a deleted record is gone from every backup within 7 days of its deletion. Call transcripts waiting to be summarised are kept in a separate store that is never backed up, so no copy of a transcript outlives its 24 hours.
  8. Make available the information needed to show compliance, and allow audits by the Controller or its auditor with 30 days' notice, no more than once a year unless a breach or regulator requires.

3. Sub-processors

The Controller authorises the sub-processors listed at https://sinewcsm.web.app/legal/sub-processors.html. The Processor will give at least 30 days' notice of a new sub-processor by email to the account owner; the Controller may object on reasonable data protection grounds, and if no solution is found may end the agreement and receive a refund of prepaid fees for the unused period. The Processor remains responsible for its sub-processors.

4. International transfers

Data is stored in the UK (London). Where a sub-processor processes it outside the UK, the transfer is protected by the UK Extension to the EU-US Data Privacy Framework where the sub-processor is certified (Resend, Sentry), or by the EU Standard Contractual Clauses with the UK Addendum (Anthropic, and Resend as well).

5. US health data

Where the Controller's clients are subject to HIPAA, the parties will agree in writing whether a business associate agreement is needed before call summaries are used for those clients. Call summaries can be switched off per client.

Annex A: security measures

PJM Apps Ltd, registered in Scotland, company number SC893991. Questions: privacy@usesinew.com.