Data processing addendum

The customer is the controller. CLWS LLC is the processor and handles personal data for the customer.

CLWS LLC processes personal data to provide the product named in the customer’s order. Processing lasts for the subscription term and any limited period needed to return or delete the data after termination.

Counterline may hold payroll, insurance, exposure, source, result and activity records about employees. Sidefile may hold identity, employment, leave, access and activity records about employees, including their medical documents.

CLWS LLC acts on the customer’s written instructions. The order, product settings and documented requests form those instructions. CLWS LLC will tell the customer if an instruction cannot be followed.

People who can access customer personal data must keep it confidential and may use it only for the work the customer has instructed CLWS LLC to perform.

The current security measures and current gaps are described on the Trust page. No third party security attestation exists yet.

The current list is on the Subprocessors page. CLWS LLC will notify the customer in writing before adding a subprocessor.

CLWS LLC will help the customer respond to a request from a person whose data is in the product. The customer remains responsible for deciding how to answer the request.

CLWS LLC will notify the customer after confirming a breach that affects customer personal data. The notification deadline has not been set in this draft. Left for counsel.

When the subscription ends, the customer may choose a return or deletion of its data, subject to its legal holds and any retention the law requires.

The customer may ask for information needed to review CLWS LLC’s handling of personal data. The scope, timing and cost terms for an audit have not been set in this draft. Left for counsel.

A business associate agreement is available where HIPAA applies. Whether Sidefile is a covered entity, or becomes one by holding documents for an employer, is a legal conclusion not made in this draft. Left for counsel.