Data processing terms

1. Parties

The organisation subscribing to GovernCore (the controller) and Nei Shot WebX Solutions CC (the processor). Where data protection law uses other words for these roles, they mean the same.

2. Subject and duration

Nei Shot hosts and processes the records the controller keeps in GovernCore, to provide the service the terms describe, for as long as the subscription lasts and the 90 days after it in which the controller may collect an export.

3. Data and data subjects

Data subjects: the controller's directors, staff and users; people named in its records, such as suppliers' contacts, people who complain, requesters and parties to legal matters; people who answer an auditor's request by link; speak-up reporters.

Personal information: names, contact details, roles, what the records say about people, signatures, sign-in records, meeting recordings and transcripts when the note taker is used, and whatever else the controller chooses to record. The controller decides whether to record special categories of information, and if it does, applies the care the law requires.

4. Nei Shot's obligations

• Process the records only on the controller's documented instructions, which are the terms, this agreement and the controller's use of GovernCore; and say so if an instruction appears unlawful.
• Make sure everyone at Nei Shot who can reach the records is bound to confidentiality and reaches them only when the service needs it, such as support the controller asked for.
• Keep the measures in section 6 in place.
• Help the controller meet its own obligations: answering requests, assessing the risks of processing, and dealing with a breach.

5. Your organisation's obligations

• Have a lawful basis for what it records and tell the people concerned, as data protection law requires.
• Give accounts only to the people who need them, with the roles they need, and remove them when they leave.
• Set the retention periods it needs under Settings, Retention.

6. Security measures

Encryption in transit; files encrypted at rest with AES-256-GCM under a key for each organisation; queries held to the organisation they are made in; access by role and by record; passwords stored as one-way hashes, account lockout and new-browser alerts; an append-only audit log sealed in a chain; encrypted offline packs that can be wiped from a distance. Security describes them in full. Nei Shot may improve them, and will not reduce the protection they give.

7. Sub-processors

The controller agrees to the sub-processors named in the data policy. Nei Shot binds each by contract to protection no weaker than this agreement and remains responsible for them. Before adding or replacing one, Nei Shot tells the controller at least 14 days ahead; the controller may object on reasonable grounds, and if the parties cannot agree, may end the subscription for the affected part without penalty.

8. Transfers outside Namibia

GovernCore is hosted in the United States, email is delivered from the European Union, and the assistant and note taker run in the United States. Nei Shot transfers records only to sub-processors bound by contract to protect them, use them only for the service, and return or delete them when asked. The controller can switch the assistant off and choose not to use the note taker, and then no records go to those providers.

9. Requests from individuals

If someone asks Nei Shot directly about records the controller keeps, Nei Shot passes the request to the controller without delay and does not answer it itself, unless the law requires. GovernCore's exports, search and privacy request register help the controller answer.

10. Breaches

Nei Shot tells the controller of a breach of security that affects its personal information without undue delay, and within 72 hours of confirming it, with what is known: what happened, what information and how many people, what has been done and who to contact. It then keeps the controller informed and helps it notify regulators and the people concerned.

11. At the end

When the subscription ends, the controller may collect a full export for 90 days. Nei Shot then deletes the records, including from storage, unless the law requires it to keep them.

12. Audit

Nei Shot gives the controller the information it reasonably needs to show compliance with this agreement. The controller, or an auditor bound to confidentiality, may audit once a year on 30 days' notice, during working hours, at its own cost, and without access to other organisations' records.

13. Law

This agreement follows the law and dispute terms of the terms. Questions to hello@neishot.com.