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Data Processing Agreement

Last updated: August 2026

This Data Processing Agreement ("DPA") is required under UK GDPR Article 28 and applies whenever a business shares employee personal data with RotaHQ. It forms part of the agreement between:

The Restaurant — the Data Controller

RotaHQ / Htet Min Aung — the Data Processor

1. Purpose

RotaHQ processes employee personal data on behalf of the restaurant solely to provide the RotaHQ service.

2. Data processed

Categories of data:

  • Employee names and contact details
  • Phone numbers
  • Work schedules and shift times
  • Clock in/out timestamps
  • Wage rates and payslip information
  • Leave requests

Data subjects:

  • Restaurant employees and managers

3. Processor obligations

RotaHQ agrees to:

  • Only process data on the restaurant's documented instructions
  • Ensure staff handling data are bound by confidentiality
  • Implement appropriate security measures
  • Not engage sub-processors without the restaurant's general authorisation (sub-processors are listed in our Privacy Policy)
  • Help the restaurant respond to data subject rights requests
  • Delete or return all data on termination
  • Provide information to demonstrate compliance with this agreement

4. Security measures

Technical measures:

  • Encryption in transit (HTTPS/TLS)
  • Encryption at rest in the database
  • Password hashing (bcrypt)
  • JWT-based authentication
  • Role-based access control
  • Tenant data isolation

Organisational measures:

  • Access limited to necessary personnel only
  • Regular security reviews
  • Incident response process

5. Data breach

In the event of a personal data breach:

  • We will notify the restaurant within 72 hours of becoming aware.
  • The notification will include the nature of the breach, categories affected, likely consequences and the measures taken.

6. Sub-processors

Authorised sub-processors:

  • Twilio Inc (WhatsApp/SMS)
  • MongoDB Inc (database)
  • Stripe Inc (payments)
  • Emergent (hosting)

7. Termination

On termination of the RotaHQ subscription:

  • Restaurant data remains available for export for 30 days.
  • After 30 days, data is permanently deleted.
  • Deletion is confirmed on request.

8. Governing law

This agreement is governed by the laws of England and Wales.

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