Data Processing Agreement.

DPA: Fiona Smalley Research
Fiona Smalley: Micro Entrepise  SIRET 88833734200016

Last revised: April 2023 

This DPA governs any processing of customer personal data provided by our clients.

The Data Processor is Fiona Smalley Research.

The Data Controller is our client who has provided the personal data.

Specific contracts are agreed on a project by project basis.


1. Purpose and Scope

 1.1 The Data Controller engages the Data Processor to process personal data on its behalf in connection with market research activities conducted by the Data Processor.


1.2 The personal data to be processed under this Agreement includes but is not limited to the data provided by the Data Controller, consisting of details of their customers/supporters who have consented to share their data for research purposes, as well as any data generated from research projects, such as video footage.


1.3 This Agreement sets out the terms and conditions governing the processing of personal data by the Data Processor on behalf of the Data Controller.


2. Obligations of the Data Processor

 2.1 Confidentiality and Security: The Data Processor shall ensure that all personal data processed on behalf of the Data Controller is kept confidential and is subject to appropriate technical and organizational security measures to protect against unauthorized access, loss, alteration, or disclosure.


2.2 Lawfulness of Processing: The Data Processor shall only process personal data in accordance with the documented instructions provided by the Data Controller, unless required to do so by applicable law. The Data Processor shall promptly inform the Data Controller if any instruction, in its opinion, infringes applicable data protection laws.


2.3 Personnel: The Data Processor shall ensure that its personnel authorized to process personal data are subject to appropriate confidentiality obligations.


2.4 Subprocessing: The Data Processor shall not engage a subprocessor without the prior written consent of the Data Controller. In the event the Data Processor engages a subprocessor, it shall impose data protection obligations on the subprocessor that are consistent with the terms of this Agreement.


2.5 Data Subject Rights: The Data Processor shall assist the Data Controller, to the extent possible, in fulfilling its obligations to respond to data subjects' requests to exercise their rights under applicable data protection laws.


2.6 Data Breach Notification: The Data Processor shall promptly notify the Data Controller of any personal data breach, providing all relevant information necessary for the Data Controller to fulfill its legal obligations.


2.7 Data Transfer: The Data Processor shall not transfer personal data to any third country or international organization without the prior written consent of the Data Controller. If such transfers are authorized, the Data Processor shall ensure appropriate safeguards are in place, such as the use of Standard Contractual Clauses or other approved mechanisms.


3. Term and Termination

3.1 This Agreement shall become effective on the date of signature by both Parties and shall remain in effect until the completion of the market research activities or until terminated by either Party in accordance with its terms.


3.2 Upon termination or completion of the market research activities, the Data Processor shall, at the choice of the Data Controller, securely delete or return all personal data processed on behalf of the Data Controller, unless applicable law requires its storage.


4. Governing Law and Jurisdiction

This Agreement shall be governed by and construed in accordance with the laws of France. Any disputes arising out of or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts of France.


5. General Provisions

Any amendments or modifications to this Agreement shall be in writing and signed by both Parties. This Agreement constitutes the entire understanding between the Parties with respect to the subject matter herein and supersedes any prior agreements or understandings, whether written or oral.