Clients data processing addendum

This addendum applies when you turn on Clients. It adds to Section 29A of our Terms, the data processing terms for Professional Records. If this addendum and Section 29A differ about client records, this addendum applies.

1. What this covers

Client records are the records you keep in Clients about the people you work with professionally: a status, a "client since" date and dated notes, each linked to one of your contacts. Client records are Professional Records under Section 29A. You are the controller of your client records. Passeri Studio Ltd (Robin) is your processor.

Section 29A applies to client records in full, including its description of the processing, our obligations as processor and your responsibilities as controller. This addendum adds the points below.

2. Health and other special-category data

Your notes can hold special-category personal data, such as details about a client's health. If you record it, you must have an Article 9 condition under the UK GDPR (or the EU GDPR where it applies). For most coaches that condition is the client's explicit consent. You must also tell your clients what you keep about them.

3. How Robin protects client records

1. A second check. Clients needs two-factor authentication (2FA) on your Robin account. Clients asks for your second factor again after a short time, so that an unattended device does not stay open. If you turn off 2FA, Clients stays closed until you turn it on again. Your records stay as they are.
2. Encryption. We encrypt the text of your notes in our database, in addition to the encryption at rest and in transit that Section 29A describes.
3. Only you. Only you can open your client records. Your clients do not see that you keep a record about them.
4. An access log. We keep a log each time your client records are opened, changed, exported or deleted. The log holds identifiers, the action, the time and the session, never names or note text. We keep it for 12 months, so that we can help you if you think someone else used your account.
5. Kept out of our tools. Client records are kept out of our analytics, session replay and monitoring tools, as Section 29A(c)(1) describes.

4. Sub-processors

You give general written authorisation for the sub-processors that our sub-processors page names for professional contacts and coaching logs to process your client records too. The rules in Section 29A(c)(4) apply, including our notice to you before an addition or a replacement.

5. Export, deletion and the bin

1. Export. You can download one client record, or all of them, at any time. Each download has a file a person can read and a file a machine can read.
2. The bin. When you delete a client record or a note, it moves to the bin. We erase it from our live systems 7 days later. You can restore it before then, or erase it straight away, for example when a client asks you to erase their data.
3. Your account. If your account is deleted, we erase your client records straight away, including anything in the bin.
4. Backups. Copies held only for recovery are put beyond ordinary use and expire with our backup rotation, as Section 29A(c)(7) describes.

6. Accepting this addendum

You accept this addendum when you tick the box and turn on Clients. We record the version you accepted and the time. If we change this addendum, we tell you before the change applies to you.