# Data Processing Agreement — Immigration Document QC (TEMPLATE)

> **Draft for review by counsel.** This is not legal advice. Replace every `[...]` field before signing.

**Client (controller):** [FIRM]
**Provider (processor):** [PRIVSIFT ENTITY]
**Effective date:** [DATE]

## 1. Purpose and roles

The Client is the **controller**; the Provider is the **processor**. The Provider processes personal data
only to provide the **Immigration Document Redact & QC** service: ingestion, OCR, PII detection/redaction,
completeness/consistency checks, reporting, and deletion.

The Client decides which documents to submit, the checklist, what is redacted, and what is produced. The
service **does not provide legal advice** and does not decide eligibility or visa outcomes.

## 2. Data

- **Categories:** immigration documents (forms, passports, birth/marriage certificates, tax records,
  medical records, affidavits), case metadata, user identifiers.
- **Sensitive data:** SSN, A-number, passport number, I-94, DOB, address, phone, email, and possible health
  data. The Client warrants it has a lawful basis to process this data.
- **No training:** the Provider does not train any model on Client documents.
- **No sale, advertising, or secondary use.**

## 3. Processing

- **Purposes:** read/OCR, mask PII, check documents and inconsistencies, produce the report, support review,
  delete.
- **Duration:** during the subscription or pilot, then deletion.
- **Subprocessors:** listed in `SUBPROCESSORS-IMMIGRATION-EN.md`; prior notice and right to object.
- **International transfers:** [SCCs / UK Addendum / Swiss Addendum] where applicable.

## 4. Security

The Provider applies the **Security Annex** (`SECURITY-ANNEX-IMMIGRATION-EN.md`): encryption, isolation,
access controls, content-free logs, zero retention, deletion certificate, and incident response.

## 5. Client rights

- Access, rectification, erasure, restriction, portability, and objection under applicable law.
- Assistance with data-subject requests.
- Audit: security questionnaire and, on reasonable notice, an audit report or attestation; never access to
  other clients' data.

## 6. Return and deletion

- The Client exports outputs before deletion.
- Documents and outputs are deleted at the end of the job or term; **default retention: 24 hours** (or
  immediately on request).
- The Provider retains only a **deletion certificate** with no content.
- Backups are deleted within [7] days.

## 7. Data breach

Notify the Client **without undue delay** and, where the GDPR applies, **within 72 hours** of discovery,
including the nature of the breach, data involved, measures taken, and contact.

## 8. Liability and term

- Liability is governed by the MSA; this DPA controls in case of conflict on data protection.
- Term = MSA term; confidentiality, deletion, and audit obligations survive.

## 9. Signature

| Client | Provider |
|---|---|
| Name: | Name: |
| Title: | Title: |
| Date: | Date: |
| Signature: | Signature: |

**Annexes:** `SECURITY-ANNEX-IMMIGRATION-EN.md`, `SUBPROCESSORS-IMMIGRATION-EN.md`.