Governance

Data Processing Agreement (DPA)

A legally binding contract between a data controller and data processor that governs the processing of personal data. Required by GDPR Article 28, a DPA specifies the scope, purpose, and duration of processing, as well as the obligations of each party.

A Data Processing Agreement (DPA) is a mandatory contractual document under GDPR that regulates the relationship between a data controller (the organization that determines the purposes and means of processing) and a data processor (the entity that processes data on the controller's behalf). The DPA must be in writing and include specific provisions required by GDPR Article 28.

Key provisions that must be included in a DPA are the subject matter and duration of processing, the nature and purpose of processing, the types of personal data and categories of data subjects, the obligations of the processor (including confidentiality, security measures, sub-processor management, data subject rights support, deletion/return of data, and cooperation with audits), and the controller's instructions for processing.

For organizations subject to both GDPR and DORA, the DPA requirements intersect with DORA's ICT third-party contractual provisions. DORA Article 30 specifies additional contractual elements for ICT services including security requirements, data location, audit rights, exit strategies, and performance monitoring — many of which complement and extend the DPA requirements.

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