Data processing

A DPA template prepared for pilot review.

This page is the procurement-facing summary of the data processing agreement. The clauses that depend on the contracting entity, hosting region, retention schedule and notification window are listed as outstanding at the bottom rather than filled with plausible-looking values.

Draft for pilot review

Draft for pilot review. This document describes how the product works today and is not a signed agreement. The final terms, data processing agreement and company details are provided and signed during onboarding.

Last revised September 2026

Controller and processor roles

ProcessingControllerProcessorNote
Supplier and site records, cases, evidence metadata, remediation actionsCustomerLiberaThe customer decides which suppliers and sites to enter and why.
Workspace user accounts and rolesCustomerLiberaThe customer invites users and assigns roles.
Worker reports submitted through the confidential channelCustomerLiberaReports are scoped to the customer's workspace. The design deliberately avoids collecting worker identity data, and the customer receives aggregated indicator counts rather than individual narratives.
Website enquiry and pilot request dataLiberaLibera decides the purpose: responding to the enquiry.

Security measures

  • Authentication through the managed authentication service, with email and password or Google sign-in; passwords are not stored by us in readable form.
  • Database-level row security policies scope every supplier record, case and report to a single workspace.
  • Role-based permissions inside a workspace: owner, compliance lead, investigator and read-only reviewer.
  • An append-only activity log of material actions — supplier added or removed, import, case opened or closed, report exported, role changed — exportable for an auditor.
  • Worker narratives are not surfaced in the management console, in exports or in the case layer.
  • HTTPS/TLS for the site and the data API; encryption at rest and backups are provided by the infrastructure sub-processors.
  • Synthetic demo content is rendered from a fixed fictional dataset in the application and never written to customer data.

Sub-processors

Supabase

Managed Postgres database, authentication and data API for organisation accounts, supplier records and worker reports.

Confirmed per deployment during onboarding — not stated here without verification.

Cloudflare

Application hosting, content delivery and execution of server functions for the website and console.

Confirmed per deployment during onboarding — not stated here without verification.

Resend

Transactional email delivery for pilot and access requests submitted through the website forms.

Confirmed per deployment during onboarding — not stated here without verification.

Deletion and return

A workspace owner can delete supplier records from the console at any time. On written request at the end of an engagement we delete the workspace and its linked records, or provide an export first. The exact schedule is fixed in the signed DPA.

Incidents and cooperation

We notify the customer contact without undue delay after becoming aware of a personal data breach affecting their workspace, with what we know at that point, and we cooperate with the customer's own regulatory obligations, data-subject requests and reasonable audit or questionnaire requests. A specific notification window is agreed in the signed DPA; we do not publish an hour count we have not committed to.

Outstanding before signature

Five values we will not guess.

  • Contracting entity and signatory:[LEGAL ENTITY NAME]
  • Hosting region and transfer mechanism:[REGION / TRANSFER MECHANISM]
  • Retention schedule per data category:[RETENTION SCHEDULE]
  • Incident notification window:[NOTIFICATION WINDOW]
  • Security and privacy contact addresses:[SECURITY CONTACT] / [PRIVACY CONTACT]

Company details

Brand name and legal details are not the same thing.

Libera Europe is the operating brand of the platform. The verified legal entity details below are not published yet. Rather than showing an unverified value, each outstanding item is marked — procurement receives the completed set before any contract is signed.

Operating brand
Libera Europe
Legal entity name
[LEGAL ENTITY NAME]To be completed before production contracting
Registered address
[REGISTERED ADDRESS]To be completed before production contracting
Chamber of Commerce number
[REGISTRATION NUMBER]To be completed before production contracting
VAT number
[VAT NUMBER]To be completed before production contracting
Governing law and jurisdiction
[GOVERNING LAW / COURT]To be completed before production contracting
General contact address
[CONTACT EMAIL]To be completed before production contracting
Privacy contact
[PRIVACY CONTACT]To be completed before production contracting
Security contact
[SECURITY CONTACT]To be completed before production contracting
Request legal & procurement details