When you are the controller and we are the processor

The short version

Module Six Ltd operates five products: the Institute of Project Professionals, Calibrate, Educate, Activate and Validate. For the first four we are the data controller. We decide what personal data is held and why, and we answer to the individuals concerned.

Validate is different. A Validate register holds competence and authorisation records about your workers, gathered so that you can show who is cleared to do what. You decide who goes on it, which competencies matter and how long the record is kept. That makes you the controller and us your processor. We process those records only on your instructions.

Owning the software does not make us the controller of what you put in it. UK GDPR decides the roles by who determines the purposes and means of the processing, and for a workforce competence register that is you.

What that means in practice

• Most people on your register have no account with us. They have never asked us for anything and have no direct relationship with Module Six. Telling them their data is held is your duty as controller, not ours.
• A worker asking to be removed asks you, not us. We cannot act on their instruction. If they come to us we will tell them to speak to you, and tell you they asked.
• We publish no retention period for register data. How long a competence record should be kept depends on your own regulatory obligations. It is your decision, not a number we set.
• At the end of the contract you choose. We return the register, delete it, or return it and then delete it. That is built and it works on your instruction, not on a schedule.

The agreement

The contract that binds us to all of the above is our standard data processing agreement. It is a single document used two ways, so the terms you get are the terms everybody gets.

If you buy Validate online

This agreement is incorporated into the terms you accept at checkout. We record which version you accepted and when, against your order. You do not need to sign anything separately, and you do not need to ask us for a copy: it is the document above.

If we set your register up for you

Where we load your workforce data on your behalf rather than you entering it yourself, we ask for a signed copy before any real person is written to your register. That is a technical block, not a promise: the import is refused until the signature is recorded.

Who else touches the data

We use a small number of suppliers to run the platform, and under the agreement they are our sub-processors for your data. They are named in the agreement, and we commit to telling you before we add or replace one so that you have the chance to object.

Your data is stored in the United Kingdom and the European Economic Area. Where a supplier processes it elsewhere, the agreement sets out the safeguard we rely on.

What we have not done

We would rather say this here than have you find it in clause 9. When you instruct us to delete a register, we delete it from our own storage, including uploaded evidence files. Copies held by our suppliers, such as an authentication account or an email delivery log, fall out on those suppliers' own retention cycles rather than immediately. The agreement says so in terms rather than promising something we cannot yet do.

Questions

Data protection questions, including anything about this agreement, go to data@modulesix.co.uk.

Module Six Ltd is registered in England and Wales, company number 17311940, at Henge Barn, Pury Hill Business Park, Alderton Road, Towcester, Northamptonshire, NN12 7LS. Registered with the Information Commissioner's Office under reference ZC198668.