Data Processing Terms for Accountancy Firms

Data protection terms for engagement letters that set out when the firm is a controller and when it is a processor, with full UK GDPR Article 28 terms and schedules.

Editable Word document
10
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

Data Processing Terms for Accountancy Firms

About this document

What it’s for

Data protection terms that sit with your engagement letter or terms of business. They explain that your firm usually acts as an independent controller for accountancy and tax work, but as a processor for some services (often payroll or bookkeeping), and give the full processor terms required by Article 28 of the UK GDPR for those services, together with schedules describing the processing, security measures and sub-processors.

When to use it

  • With every new engagement letter, or as a schedule to your standard terms of business
  • When a client (often a larger business) asks for a data processing agreement
  • When you update terms after the Data (Use and Access) Act 2025 changes

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Definitions and interpretation
  2. Scope and roles
  3. Where the firm acts as controller
  4. Where the firm acts as processor
  5. Sub-processors
  6. Security
  7. Data subject rights and complaints
  8. Personal data breaches
  9. International transfers
  10. Audit and information
  11. Retention, return and deletion
  12. Legal and regulatory obligations
  13. Client obligations
  14. Liability
  15. Duration and changes
  16. Governing law

Also included

  • Schedule 2 – Security measures
  • Schedule 3 – Approved Sub-processors
  • Acceptance

How to complete it

  • Decide your role for each service and complete Schedule 1
  • Describe your actual security measures in Schedule 2 and list your real sub-processors in Schedule 3
  • Check the cross-references to your engagement letter and privacy notice
  • Incorporate by reference in the engagement letter, or have both parties sign

Key points to check

  • The UK regulator became the Information Commission on 30 September 2026
  • Controllers have had to handle data protection complaints directly since 19 June 2026

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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