Pactora Clause Guide

Data Protection

The data protection clause sets out how personal data is handled under the contract, who is the data controller, who is the data processor, and what obligations each party owes under UK GDPR and the Data Protection Act 2018.

This guide was written by Sneha Ganapavarapu, a qualified lawyer with experience in commercial contracts across technology, IP, and energy sectors. All legal sources are linked. This is general legal information, not legal advice. Always consult a qualified solicitor before signing any contract that matters to your business.

Plain English

What it is

The data protection clause sets out how personal data is handled under the contract, who is the data controller, who is the data processor, and what obligations each party owes under UK GDPR and the Data Protection Act 2018.

For UK freelancers & small businesses

What reasonable looks like

  • Clear identification of who is controller and who is processor.

  • Processor obligations set out — process only on documented instructions, implement appropriate security measures, assist with subject access requests, notify of breaches within 72 hours, delete or return data on termination.

Watch out for

Red flags

No data protection clause at all in a contract involving personal data.

Clause that makes you responsible as controller when you are clearly acting as processor.

No breach notification obligation.

No deletion or return of data on termination.

England & Wales

Market standard UK position

UK GDPR compliant processor terms.

Clear controller/processor distinction.

72-hour breach notification.

Data deletion or return on termination.

Legal advice triggers

Ask your lawyer if…

The contract involves personal data and has no data protection clause.

You are being made controller when you are acting as processor.

References

Legal sources

Read more

Further reading

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Further reading

Related clause guides