- Before
- 14 open DPA reviews, every one urgent for someone; reads 30-page supplier papers to find eight terms.
- Now
- Opens a scorecard with every term quoted and the redline already checked, asks the agents why, and approves with a reason code.
One supplier DPA, from the morning briefing to a signed redline
Cloudhaven Analytics, a workforce-analytics supplier in London, sends its paper for 38,400 employee and contractor records in 14 countries: a three-year order worth €412,000, with go-live wanted on Mon 2 Nov. Privacy counsel Tomás Ibarra works through it with the review team in one conversation. Here is what happens, screen by screen, in the working solution.
- 01Wed 14 Oct, morning
A briefing, and a review team to talk to
Tomás Ibarra · Privacy counselOvernight the agents read 3 supplier packages and 9 sub-processor notices. Today shows 14 open reviews, 4 that need Tomás in the order the agents suggest, and what they found since yesterday. Beside it, the review team's conversation: the positions agent asked the DPO whether absence reason codes are special category data, and Ingrid Halvorsen answered at 08:15.
Ingrid Halvorsen: “Yes, treat it as health data. List it in Annex 1 and set the DPIA flag.”
- 02Open Cloudhaven
Fifteen checks, each quoted from wherever it sits
Clause agentThe Article 28 scorecard lists 15 checks with the clause quoted and a chip for the document it came from: Cloudhaven DPA v3.2 (14 pages), the Master Subscription Agreement (31 pages), Security Schedule v2.4 (9 pages) and the sub-processor page captured on 12 Oct. Confidentiality is in MSA §11.2 and security in the separate schedule; DPA §1.3 decides which prevails. Result: 6 found, 2 within fallback, 5 weaker, 2 missing.
“Checker agrees · 15 of 15 quotes verified”
- 03Watch the agents
How the scorecard was built, step by step
The review teamTomás can replay the overnight run. The intake agent paired 4 documents with order CH-OF-2291 and found the role: processor. The clause agent found 13 of 15 terms across 54 pages. The transfer agent checked 7 hops, the counterparty agent read the 2024 negotiation, the redline agent drafted 7 changes, and the checker re-read everything on its own.
Last step: “Waiting for you · Tomás Ibarra”, with 4 counsel-tier changes and the package for him to approve.
- 04Check 10
Breach notice: 30 days, beyond walk-away
Positions agentDPA §10.1 reads “within thirty (30) days of confirming such breach.” The drawer shows the reasoning, the three positions from P-10 — preferred within 48 hours, fallback within 72 hours, walk-away more than 72 hours or “after confirming” — and where the supplier sits. It also shows what Cloudhaven did before: likely to resist (80%), having held breach notice at 72 hours in 2024.
“We must tell the regulator within 72 hours (Art. 33(1)). Thirty days after ‘confirming’ makes that impossible.”
- 05Transfers
Six hops covered, one with no mechanism
Transfer agentThe transfer agent follows the data from K&V Services GmbH to Cloudhaven in London (UK adequacy) and on to 6 sub-processors, checking adequacy, the Data Privacy Framework list, SCC modules and transfer assessments. Sarvik Support Services in Pune, India gives tier-2 support with access to tickets and, on request, the customer environment — on “appropriate safeguards” only, with no Module 3 and no TIA. Counsel chooses the remedy.
Recommended remedy: “Ask for SCC Module 3 and a transfer assessment within 30 days” — the P-14 preferred position.
- 06The redline
Seven changes, only from Positions v7
Redline agentThe redline package holds 7 tracked changes — P-02, P-04, P-07, P-10, P-12, P-14 and P-15 — 4 of them counsel-tier. Each carries its position and version, the counterparty prediction and the checker's word: verbatim. The cover note to Cloudhaven's legal team is drafted and editable, asking for a reply by Monday 19 October so the service can start on 2 November.
The redline agent never writes free-text legal language, and never sends.
- 07He asks
“Why 48 hours, not 72?”
Tomás Ibarra · Privacy counselTomás asks in the conversation beside the scorecard. The positions agent answers with numbered citations: the controller must tell the regulator within 72 hours, so if Cloudhaven also takes 72 the time is gone before he hears. P-10 opens at 48. Cloudhaven held 72 in 2024, so 72 is ready as the approved fallback for round 2 without going back to the DPO.
- 08One click
Every citation opens its source
Tomás Ibarra · Privacy counselEach number in an answer opens the passage it rests on, with the quote highlighted — here GDPR Article 33(1), read by the clause agent and verified by the checker. The same works for any clause of the supplier's DPA, master agreement or schedule.
- 09The decision
Approve with a reason code
Tomás Ibarra · Privacy counselApproving the package opens the 7 changes with their tiers, a reason code — RC-01 “Matches our preferred positions” through RC-06 “Rejected: outside walk-away” — an optional note for the audit trail, and a confirmation he must tick. He picks RC-01: 48 hours stays the opening position, 72 the fallback ready.
“I have read the 4 counsel-tier changes and their sources”
- 10Signed · 09:42
Sent to the supplier, and procurement knows
Tomás Ibarra · Privacy counselThe redline goes to Cloudhaven's legal contact with the cover note at 09:42, signed RC-01. The counterparty agent watches the inbox for the reply, expected by Mon 19 Oct. Marcus Adeyemi, the procurement contract manager, sees “Redline sent, reply expected Mon 19 Oct”, and the purchase request stays on hold until the DPA is agreed.
“Signed by Tomás Ibarra · redline sent to Cloudhaven”