Data Processing Addendum (DPA)

Last updated: May 2026

This Data Processing Addendum (“DPA”) forms part of the agreement between you (“Customer”) and Governing Idea (“Processor,” “we,” “our,” or “us”). It describes how we process personal data on your behalf in accordance with Article 28 of the EU General Data Protection Regulation (GDPR).

1. Roles

Customer is the data controller. Governing Idea is the data processor that processes personal data solely to provide the writing coach service.

2. Processor Obligations

• Process personal data only on documented instructions from Customer.
• Maintain appropriate technical and organizational security measures.
• Ensure confidentiality of personnel with access to personal data.
• Assist Customer with data subject requests where feasible.
• Notify Customer without undue delay in the event of a data breach.
• Delete or return personal data upon request or termination.

3. Subprocessors

We use subprocessors to support hosting, email delivery, and infrastructure. A current list is available on our Subprocessors page.

4. International Transfers

When transferring personal data outside the EU or UK, we rely on the EU–US Data Privacy Framework where applicable and Standard Contractual Clauses (SCCs) with subprocessors.

5. Term and Termination

This DPA remains in effect as long as we process personal data on behalf of Customer. Upon termination, we will delete or return personal data unless legally required to retain it.