Data Processing Addendum
This summary describes how the platform DPA works. It is an overview; the executed DPA attached to your subscription agreement governs. Its defining feature: because raw data never leaves your environment, GateHouse’s role as processor is unusually narrow.
1 · Roles
For personal data within customer datasets, the customer is the controller and GateHouse is the processor. GateHouse processes such data only on documented instructions — and, in practice, only ever inside the customer’s own environment.
2 · Nature of processing
Processing is limited to: profiling and policy evaluation inside the container; admitting and metering workloads; and coordinating metadata that has passed the customer’s disclosure gate. Raw records are not transmitted to GateHouse.
3 · Sub-processing
GateHouse engages sub-processors only under written terms no less protective than the DPA, and maintains the current list on the Subprocessors page with advance notice of changes.
4 · Security measures
- Metadata-only control plane; raw data confined to the customer environment.
- ABAC policy enforcement (Cedar) with enforcement and attestation modes.
- Encryption in transit and at rest for all metadata GateHouse holds.
- Settlement-grade audit logging of policy, egress and admin events.
- Time-boxed, customer-granted delegated support access with full session logs.
5 · International transfers
Default EU/UK residency; Standard Contractual Clauses where a transfer is required. Because raw data stays in the customer environment, cross-border movement of customer personal data is minimised by design.
6 · Assistance & audits
GateHouse assists the controller with data-subject requests, DPIAs and regulator engagement — including attestation outputs — and makes available information necessary to demonstrate compliance, subject to reasonable audit terms.
7 · Return & deletion
On termination, GateHouse deletes or returns metadata it holds. Customer datasets require no return: they never left the customer’s environment.