Data Processing Addendum

Data protection and processing terms under GDPR/UK GDPR compliance

Last updated

22 August 2025

This DPA forms part of the Merra Terms of Service and applies automatically to any workspace that processes Candidate Data.

1) Parties & Roles

  • Customer acts as Data Controller.
  • Merra Ai Ltd acts as Data Processor.

2) Subject Matter, Nature, Purpose, Duration

  • Subject matter: processing of Candidate and Customer user personal data in connection with Merra's interview platform.
  • Nature & purpose: capture of short voice/video interviews, transcription, scoring, evaluation, storage, and display to authorised users.
  • Duration: for the term of the agreement and any post-termination retention set by the Controller or required by law.

3) Processor Obligations

Merra shall:

  • process personal data only on Controller's documented instructions;
  • ensure personnel are bound by confidentiality;
  • implement security measures appropriate to risk (Art. 32), including encryption and access controls;
  • assist Controller with data subject requests, breach notifications, DPIAs, and supervisory consultations as reasonably required;
  • delete or return personal data at the end of the Services per Controller instruction;
  • make available information needed to demonstrate compliance and allow reasonable, scoped audits (on notice, during business hours, without accessing other customers' data).

4) Sub-processors

Controller authorises Merra to use sub-processors for hosting, storage, communications, and AI inference. Merra will impose equivalent data-protection obligations on sub-processors and remains responsible for their performance. Merra will maintain a list of current sub-processors (available at /sub-processors or on request) and notify Controller of material changes.

5) International Transfers

If personal data is transferred outside the UK/EU, Merra will implement appropriate safeguards (e.g., EU Standard Contractual Clauses and UK Addendum) and conduct transfer impact assessments as required.

6) Security Measures

Merra maintains technical and organisational measures including:

  • Encryption in transit and at rest;
  • Role-based access and least privilege;
  • Audit logging for admin actions;
  • Vulnerability management and patching;
  • Backups and tested restores;
  • Incident response and breach notification procedures.

7) Breach Notification

Merra will notify Controller without undue delay after becoming aware of a personal-data breach and provide information reasonably available to assist Controller's obligations (including Articles 33/34 GDPR/UK GDPR).

8) Retention, Return & Deletion

Default retention is video/audio 30 days, transcripts & scores up to 12 months. Upon termination/expiry or at Controller's request, Merra will delete or return personal data (unless retention is required by law). Deletion is performed using industry-standard processes.

9) Controller Responsibilities

Controller is responsible for: establishing a lawful basis; providing required notices to data subjects; configuring retention and access; and ensuring human oversight of AI-assisted outputs before taking decisions.

10) Liability, Law & Venue

This DPA is governed by the law and jurisdiction in the ToS (England & Wales). Each party's liability under this DPA is subject to the limitations in the ToS.

Annexes

Annex A — Data Details

  • Data subjects: job applicants/candidates; Customer's authorised users.
  • Categories of data: identification (name, email), interview video/audio, transcripts, scores/evaluations, and usage metadata.
  • Special categories: not intentionally processed; Controller must avoid collecting special-category data unless strictly necessary and with a lawful basis.

Annex B — Sub-processors

Merra's current sub-processors are listed at /sub-processors (or available on request), including hosting, storage, email, and AI inference providers.