Freelancer Data Processing Terms (Article 28 UK GDPR)

Concise data processing terms for freelancers who handle personal data on behalf of clients – subject matter and instructions, confidentiality, security measures, sub-processors, international transfers, assistance, breach notification, deletion and audit – with a processing schedule.

Editable Word document
4
10pages
Guidance notes included
aml consultancy solutions

Freelancers & contractors

Freelancer Data Processing Terms (Article 28 UK GDPR)

About this document

What it’s for

Many freelancers handle clients’ personal data – customer lists, employee records, website user data, email marketing lists or bookkeeping records. When you process personal data on behalf of a client, UK GDPR requires a written contract containing specific terms. Clients increasingly ask for these, and having your own ready shows professionalism.

When to use it

  • When you will access or handle personal data for a client (bookkeepers, VAs, developers, marketers, designers working with customer data)
  • As a schedule to your services agreement
  • When a client asks you to sign their data processing agreement – use this to check it

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. Scope
  2. Processor obligations
  3. Controller obligations
  4. Liability

How to complete it

  • Complete the processing schedule for each client
  • List the tools and services you use that store the data (sub-processors)
  • Make sure your security measures are realistic and actually in place

Key points to check

  • If you decide what data to collect and why, you may be a controller, not a processor
  • You may need to pay the ICO data protection fee – check the ICO’s self-assessment tool

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.

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Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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