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Third-Party Data Processing

Responsible sharing. Protected potential.

BrainSeeds may work with carefully selected technology and service partners to help deliver a modern talent identification, psychometric assessment and personalised learning platform.

Effective Date: [Insert Date]
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Our Core Principle

Third parties may help us deliver our services. They should never be given unnecessary access to the personal information entrusted to BrainSeeds.

A connected service ecosystem

BrainSeeds may work with specialised partners across technology, communications, security, payments, support and other legitimate service functions.

Cloud hosting
Data storage
Assessment technology
Software infrastructure
Artificial intelligence & analytics
Communication services
Email & messaging
Payment processing
Cybersecurity
Website analytics
Customer support
Technical maintenance
Reporting & business intelligence
Identity verification
Backup & disaster recovery
Understanding the Relationship

A third party can support BrainSeeds without becoming a BrainSeeds user.

Third-party data processing occurs when an external organisation processes personal information in connection with services provided to or for BrainSeeds.

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Section 2

What is third-party data processing?

An external organisation may process information as part of delivering a service connected with BrainSeeds. The organisation does not necessarily have to be a BrainSeeds customer or user.

Technology provider May host BrainSeeds systems.
Communication provider May deliver an assessment notification or programme-related email.

The legal role depends on the relationship and applicable framework.

Depending on the relationship and applicable law, a third party may act in different capacities.

A service provider
A data processor
A technology provider
A sub-processor
An independent data controller
A professional adviser
A payment service provider
A security or compliance provider
The legal role of a particular organisation depends on the nature of the processing and the applicable legal framework.

Why BrainSeeds uses third-party service providers

BrainSeeds may engage specialised providers where doing so helps operate the platform securely, reliably and effectively.

The policy identifies a range of potential purposes rather than implying that every provider performs every function.

01

Technology Infrastructure

Hosting applications, databases and digital services.

02

Data Storage

Securely storing information required to provide BrainSeeds services.

03

Assessment Technology

Supporting assessment administration, scoring or related technical functionality.

04

Artificial Intelligence & Analytics

Supporting analysis, personalisation, reporting or recommendations where appropriately configured and permitted.

05

Communication

Sending account notifications, assessment invitations, reports, programme information and service communications.

06

Payments

Processing fees and transactions through specialised payment providers.

07

Security

Supporting monitoring, threat detection, authentication and protection against unauthorised activity.

08

Customer Support

Helping BrainSeeds respond to user enquiries and service requests.

09

Analytics

Understanding website and platform performance and improving user experience.

10

Backup & Disaster Recovery

Maintaining appropriate resilience and recovery capabilities.

11

Professional Services

Supporting legal, accounting, audit, compliance or other legitimate professional requirements.

Data Flow & Purpose

The service determines the data.

BrainSeeds may work with different categories of external providers. The information shared should generally reflect what is reasonably required for the authorised function being performed.

Categories of third parties

BrainSeeds may work with different categories of external providers. The policy describes categories rather than guaranteeing that every category is used at all times.

01

Cloud & Hosting Providers

Infrastructure, hosting and storage

02

Database Providers

Secure data storage and management

03

Assessment Technology Providers

Assessment administration and scoring support

04

AI & Analytics Providers

Analysis, personalisation and reporting

05

Communication Providers

Email, SMS and other communications

06

Payment Providers

Payment processing

07

Security Providers

Cybersecurity and monitoring

08

Backup Providers

Data resilience and disaster recovery

09

Analytics Providers

Website and service analytics

10

Customer Support Providers

User support and service management

11

IT & Development Providers

Software development and maintenance

12

Professional Advisers

Legal, accounting, audit and compliance support

13

Verification Providers

Identity or account verification where necessary

14

Government / Regulatory Authorities

Compliance with legal obligations where required

This category list describes potential categories rather than guaranteeing that every category is used at all times.
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Minimum necessary access

A third-party provider should generally receive only the information reasonably required to perform its authorised function.

Purpose determines access.
Communication provider May need name, email address, telephone number and communication preferences.
Payment provider May need information necessary to process a transaction.
A communication provider would generally not need access to an individual's complete psychometric profile simply to deliver an email.

What may be processed depends on the service

Depending on the service, third-party providers may process limited categories of information.

Name
Contact information
Account information
Educational information
Programme information
Assessment identifiers
Assessment responses
Assessment results
Learning and development information
Career-interest information
Communication records
Payment-related information
Technical information
Device and browser information
Security and authentication information
The exact information shared depends on the service being provided. BrainSeeds seeks to avoid sharing information that is unnecessary for the relevant purpose.
Sensitive Information

Some information deserves a different level of care.

BrainSeeds recognises that assessment information can be particularly sensitive from a personal-development perspective, and that children and students require additional consideration.

Assessment information is not ordinary marketing data.

Assessment information may include insights relating to cognitive abilities, Multiple Intelligence areas, personality, learning preferences, emotional intelligence, behavioural characteristics, career interests, aptitudes, competencies and development areas.

01

Abilities & Aptitudes

Cognitive abilities, aptitudes and competencies may form part of assessment information.

02

Personal Characteristics

Personality, emotional intelligence and behavioural characteristics may be represented.

03

Learning & Development

Learning preferences, career interests and development areas may be included.

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Where processing is required, access should be tightly defined.

BrainSeeds seeks to ensure that access to assessment information is purpose-specific, authorised, limited, secure and confidential, with contractual control where appropriate.

Purpose-specific
Authorised
Limited
Secure
Confidential
Contractually controlled where appropriate
Assessment information should not be treated like ordinary marketing data.

Additional consideration for children and students

Where third-party services are used in connection with student programmes, BrainSeeds seeks to apply appropriate safeguards.

Data minimisation Access control Confidentiality Security Appropriate contractual arrangements Parental or guardian involvement where required Applicable consent requirements Responsible use of assessment information
Third-party providers should not use children's or students' information for unrelated purposes merely because they have technical access to it.

Third-Party AI Providers

BrainSeeds may use external artificial intelligence, machine-learning or analytics technologies as part of its technology ecosystem.

Where technically and contractually appropriate, BrainSeeds will seek to prevent third-party AI providers from using personal information for unrelated purposes.

Factors BrainSeeds seeks to evaluate

Security
Privacy controls
Data-use practices
Confidentiality
Data retention
Sub-processing
International data transfers
Access controls
Ability to limit provider use of information
Contractual protections
Suitability for the intended purpose

AI can assist.
Accountability remains human.

The use of a third-party AI or technology provider does not transfer accountability away from BrainSeeds.

“An algorithm cannot be accountable. People must be.”

BrainSeeds seeks to maintain appropriate human oversight over significant assessment, developmental and personalised learning processes. AI-generated or algorithmically supported information should be interpreted within the appropriate context and should not automatically be treated as a definitive statement about an individual's potential.

Governance Layer

Trust is reinforced by contracts, confidentiality and controlled access.

BrainSeeds seeks to establish appropriate contractual controls with relevant third-party providers and limit access to authorised personnel with a legitimate business or service-related need.

Section 11 · Contractual Safeguards

The provider relationship should define how information is handled.

Where appropriate, BrainSeeds seeks to establish contractual controls with third-party providers. Depending on the nature of the relationship, contractual requirements may address the following areas.

Purpose of processing
Confidentiality
Data security
Access restrictions
Data minimisation
Data retention
Deletion or return of information
Sub-processing
Security incidents
Assistance with privacy requests
Compliance responsibilities
International data transfers
Restrictions on unauthorised use
The exact contractual requirements may differ depending on the type of provider and applicable law.

Section 12 · Confidentiality Requirements

Access only where necessary for authorised activities.

Individuals working for or with third-party providers may have access to BrainSeeds information only where necessary for authorised activities.

Employees
Contractors
Technical specialists
Support personnel
Consultants
Professional advisers
Sub-processors
Where appropriate, confidentiality obligations may apply to these individuals and organisations.
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Section 13

Third-Party Access Controls

BrainSeeds seeks to ensure that third-party access is appropriately controlled.

Role-based access
Account authentication
Least-privilege access
Restricted administrative permissions
Access logging
Periodic access review
Secure credentials
Multi-factor authentication where appropriate
Removal of access when no longer required
Technical controls will depend on the nature of the service and the technology involved.
Provider Assurance

The provider should match the sensitivity of the data.

BrainSeeds may evaluate third-party providers that handle BrainSeeds information based on their ability to provide appropriate safeguards, while considering the nature and sensitivity of the information processed.

Section 14 · Security Requirements

Appropriate safeguards across the provider relationship

Depending on the service, third-party providers may be evaluated against security capabilities relevant to protecting BrainSeeds information.

Encryption
Secure transmission
Access controls
Network security
Monitoring
Vulnerability management
Backup and recovery
Incident response
Secure development practices
Physical security
Business continuity
BrainSeeds will seek to use providers whose security practices are appropriate to the sensitivity and nature of the information being processed.

Section 15

Sub-processors

Some third-party providers may themselves use additional service providers. These organisations may be referred to as sub-processors where applicable.

Where appropriate, BrainSeeds seeks to ensure that sub-processors are subject to suitable contractual and security requirements.

What BrainSeeds may manage

Sub-processor oversight can extend across the relationship

Identifying relevant sub-processors
Assessing their role
Managing authorisation
Maintaining appropriate contractual protections
Reviewing significant changes
Addressing privacy or security concerns

Section 16 · Provider Use of Data

Processing for BrainSeeds does not automatically mean permission for unrelated use.

BrainSeeds does not intend that a service provider may freely use BrainSeeds personal information for unrelated purposes merely because the provider processes that information on our behalf.

When acting on behalf of BrainSeeds Use of information should be limited by the relevant service relationship, contractual requirements and applicable law.
When acting independently A provider may have separate privacy responsibilities, which should be explained through its own privacy documentation where applicable.
The role of the provider matters: processing information for BrainSeeds is distinct from independently using information for the provider's own purposes.

Section 17 · Payment Processing

Specialised providers may handle transaction processing.

BrainSeeds may use specialised payment providers to process transactions.

BrainSeeds → Payment provider → Transaction

Information that may be processed

Transaction-related information

Name
Contact information
Transaction details
Billing information
Payment identifiers
Other information necessary to complete or verify a transaction
Where payment-card information is handled by a third-party payment provider, BrainSeeds seeks to minimise its direct handling of sensitive payment information.

Users should also review the applicable payment provider's privacy information where appropriate.

Governance Layer

Trust is reinforced by contracts, confidentiality and controlled access.

BrainSeeds seeks to establish appropriate contractual controls with relevant third-party providers and limit access to authorised personnel with a legitimate business or service-related need.

Section 11 · Contractual Safeguards

The provider relationship should define how information is handled.

Where appropriate, BrainSeeds seeks to establish contractual controls with third-party providers. Depending on the nature of the relationship, contractual requirements may address the following areas.

Purpose of processing
Confidentiality
Data security
Access restrictions
Data minimisation
Data retention
Deletion or return of information
Sub-processing
Security incidents
Assistance with privacy requests
Compliance responsibilities
International data transfers
Restrictions on unauthorised use
The exact contractual requirements may differ depending on the type of provider and applicable law.

Section 12 · Confidentiality Requirements

Access only where necessary for authorised activities.

Individuals working for or with third-party providers may have access to BrainSeeds information only where necessary for authorised activities.

Employees
Contractors
Technical specialists
Support personnel
Consultants
Professional advisers
Sub-processors
Where appropriate, confidentiality obligations may apply to these individuals and organisations.
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Section 13

Third-Party Access Controls

BrainSeeds seeks to ensure that third-party access is appropriately controlled.

Role-based access
Account authentication
Least-privilege access
Restricted administrative permissions
Access logging
Periodic access review
Secure credentials
Multi-factor authentication where appropriate
Removal of access when no longer required
Technical controls will depend on the nature of the service and the technology involved.
Connected Services

Communication, insight and professional expertise — connected with purpose.

BrainSeeds may use specialised providers to support communications, website and platform analytics, and legitimate professional requirements.

Section 18 · Communication Providers

External communication providers may deliver essential service messages.

BrainSeeds may use external providers to send communications connected with assessments, accounts, programmes, learning and transactions.

Assessment invitations
Account notifications
Verification messages
Programme communications
Learning reminders
Service updates
Support responses
Transactional messages
Marketing communications will be handled according to applicable preferences and legal requirements.

Section 19 · Analytics & Website Technology

Understand performance. Improve the experience.

BrainSeeds may use third-party analytics and website technologies to understand aspects of website and platform performance.

Website performance
Visitor interactions
Technical problems
General usage trends
Service performance
User experience

Appropriate configuration

Analytics should remain focused on relevant service insight.

BrainSeeds seeks to configure analytics tools appropriately and avoid collecting unnecessary personal information.

Section 20 · Professional Advisers

Limited disclosures may support legitimate professional requirements.

BrainSeeds may disclose limited information to professional advisers where reasonably necessary, subject to applicable confidentiality and legal requirements.

Lawyers
Accountants
Auditors
Compliance advisers
Cybersecurity specialists
Insurance advisers
Other professional consultants
Such disclosures will be limited to what is reasonably necessary for the relevant professional purpose, subject to applicable confidentiality and legal requirements.
Privacy Beyond Our Boundary

A provider's privacy practices can be separate from ours.

Some third-party providers maintain their own privacy policies. BrainSeeds' policy explains BrainSeeds' handling of personal information, while a provider's own policy explains that provider's practices.

Section 24 · Third-Party Privacy Policies

Understand which organisation's practices apply.

Payment, communication, analytics or technology providers may independently publish information describing their processing activities.

01

BrainSeeds Privacy Policy

Explains BrainSeeds' handling of personal information.

02

Provider Privacy Policy

Explains that provider's own practices.

03

Independent Organisations

Some third parties may act independently rather than solely on behalf of BrainSeeds.

BrainSeeds does not control the privacy practices of independent organisations outside our contractual or operational authority.

Section 25

Personal assessment information should not become a commodity.

BrainSeeds' objective is not to create commercial markets around highly personal assessment and development information.

Children's psychological profiles
Personal talent profiles
Individual personality information
Private developmental information
Assessment responses
Personal career profiles

Legitimate, authorised purposes

Processing by service providers should remain connected to the authorised purpose.

Where information is processed by service providers, BrainSeeds seeks to ensure that it is used for legitimate, authorised purposes rather than unrelated commercial exploitation.

The purpose of the service relationship remains central to how BrainSeeds approaches third-party processing.
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Section 26 · Data Retention by Third Parties

Retention expectations should continue through the end of the relationship.

BrainSeeds seeks to establish appropriate retention and deletion expectations with relevant service providers. When a service relationship ends, BrainSeeds may seek to ensure that personal information is handled through appropriate return, deletion, destruction or anonymisation measures.

Returned
Deleted
Securely destroyed
Anonymised where appropriate
Some information may remain temporarily in secure backups, archives or systems where immediate deletion is technically impractical or where retention is required by law. The BrainSeeds Data Retention & Deletion Policy provides further information.

Section 27 · Privacy Requests

Privacy requests may require coordination across the service ecosystem.

If you submit a privacy request to BrainSeeds, we may need to work with relevant service providers to locate, correct, export or delete information.

Privacy request submitted
Relevant information located
Appropriate parties coordinate

Depending on the nature of the processing

Different participants may have a role.

BrainSeeds may handle the request directly
A service provider may be asked to assist
An educational institution or organisation may need to participate
Legal or contractual restrictions may apply
BrainSeeds' objective is to make the process as straightforward as reasonably possible for the individual. Please refer to the Data Subject Rights / Privacy Request Policy for details about submitting a request.
Third-Party Risk

When something changes, risk management changes with it.

BrainSeeds seeks to assess third-party incidents, manage provider risk through the engagement lifecycle, and apply greater care where more sensitive information is involved.

Section 28

Security incidents involving third parties

If BrainSeeds becomes aware of a security incident involving a third-party provider that affects BrainSeeds information, we will assess the incident and take appropriate action.

The response will depend on the nature, scope and legal implications of the incident.

Depending on the circumstances

Possible response activities

Investigating the incident
Working with the provider
Containing the issue
Assessing affected information
Strengthening security controls
Meeting applicable notification requirements
Communicating with affected individuals where required or appropriate

Section 29 · Third-Party Risk Management

Provider risk is considered before, during and at the end of an engagement.

BrainSeeds seeks to consider privacy and security risks when selecting and managing important third-party providers. The level of assessment may depend on the provider and level of risk.

01

Before Engagement

Nature of services
Type of information involved
Security capabilities
Privacy practices
Data location
Sub-processors
Contractual safeguards
02

During Engagement

Access management
Performance
Security events
Compliance requirements
Material service changes
03

At the End of Engagement

Access termination
Data return
Data deletion
Credential revocation
Closure of integrations
Not every provider will require the same level of assessment.
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Section 30 · Higher Standards for Sensitive Information

The more sensitive the information, the greater the care that should be applied.

BrainSeeds may therefore apply additional scrutiny to providers processing information that requires heightened protection.

Children's information
Assessment responses
Psychometric information
Behavioural information
Developmental profiles
Career-related profiles
Authentication information
Other information requiring heightened protection