How this agreement applies
This standard Data Processing Agreement applies when incorporated into your signed order form. The order form identifies the hosting option, applicable service terms and any engagement-specific processing instructions. Where documents differ, the signed order form and this DPA govern as stated in that order.
1. Roles
You (the operator or licence holder) are the controller of the personal data in your registers and integrity records. FEEC is the processor. Where FEEC uses a sub-processor, that party acts under FEEC’s instructions and the terms in section 5.
2. What we process
- Well, facility and register data, including wellbore, casing, cement, completion, barrier and annulus records.
- Annulus pressure readings, fluid data and bleed-off records.
- Well integrity test records, including the test values and acceptance reference recorded in the app.
- Assessment runs and tenant-policy change requests and approvals.
- Account data for your users: name, work email, role, and authentication events.
- Personal data that happens to appear inside an engineering document, such as a name against a test sign-off.
3. What we do with it
We process your data only to provide and support the service and to comply with law. We do not sell it, use it for advertising, use it to train models or disclose it to another customer.
4. Where it is held
A live customer register is held only on BarrierLedger’s production hosting, never on demonstration, staging or other shared FEEC infrastructure. Depending on the hosting option in your order form, your data is held on the multi-tenant production platform (each tenant isolated in the database by row-level security), on an isolated dedicated server and database managed by FEEC, or inside your own infrastructure under a self-hosted licence. Backups are encrypted. The hosting option, backup retention and recovery expectations are recorded in the order form.
International transfers (subject to legal review, D37 (9)). FEEC’s off-site backups are held in the EU. Where your data is processed outside your own jurisdiction, the transfer mechanism that applies (for example the EU standard contractual clauses or the UK addendum) will be set out in your order form. This paragraph is a placeholder until the order form and this agreement have been reviewed by counsel.
5. Sub-processors
The sub-processors engaged for a BarrierLedger engagement are listed on the Sub-processors page, with what each one does. We will tell you before a new sub-processor is engaged for your data, and you may object.
6. Security
Technical and organisational measures include tenant isolation enforced in the database with row-level security, one-time codes at sign-in (required for every user where the customer chooses), role-based access, encrypted backups, and assessment records carrying the input and method/settings versions used. Policy change requests and approvals are attributed to the account and role. FEEC holds no certification for BarrierLedger and claims none.
7. Your obligations
You are responsible for the lawfulness of the data you give us, for the accuracy of the register, readings and limits, for your own regulatory submissions and official well records, and for the roles you assign to your users.
8. Assistance and rights
We help you answer data subject requests, and we pass on a request that reaches us directly. We assist with impact assessments and prior consultations where the law requires it.
9. Personal data breach
We notify you without undue delay after becoming aware of a personal data breach affecting your data, with what we know: what happened, what data is involved, the likely consequences, and what we have done or propose to do. We keep a record of the breach and of the response.
10. Return and deletion
At the end of an engagement, you may request an export of your tenant records under the order form; the export format is agreed for that deployment, and we provide it within 30 days of your request. On request we delete your data and confirm it in writing, subject to any legal retention obligation, which we will tell you about at the time.
Deletion and backups. Deleted data is erased from live systems within 60 days of your request. Copies in our encrypted backups are not edited; they are erased when the backup retention expires, at most 12 months after the deletion. Until then they are kept encrypted and are used only to restore the service after a failure, never to bring deleted data back into use.
11. Audit
You may ask for the information you need to satisfy yourself that we process your data as agreed. Where a visit is needed it is arranged in advance, at a reasonable time and cost, and under confidentiality.
12. Contact
Data-protection questions and notices under these terms go to privacy [at] barrierledger.com; contractual notices to legal [at] barrierledger.com. The signed order form may name further contacts.