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.

Privacy Terms Data processing Contact & company Trust center Security

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

Processing	Controller	Processor	Note
Supplier and site records, cases, evidence metadata, remediation actions	Customer	Libera	The customer decides which suppliers and sites to enter and why.
Workspace user accounts and roles	Customer	Libera	The customer invites users and assigns roles.
Worker reports submitted through the confidential channel	Customer	Libera	Reports 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 data	Libera	—	Libera decides the purpose: responding to the enquiry.

Subject matter and processing details

The subject matter is the customer’s use of Libera for supply-chain screening, confidential worker signals, human review, case documentation and remediation follow-up. Duration follows the service agreement plus the agreed return/deletion period. Frequency and scope depend on the selected pilot or subscription.

Organisation and account records

Workspace name, account email, role and authentication/session records handled by the managed authentication service.

Suppliers and sites

Names, country, sector, workforce and recruitment context entered or imported by the customer.

Cases and evidence metadata

Case status, timelines, evidence titles/sources/references and investigation notes. The case layer does not copy worker narratives.

Remediation records

Actions, owners, due dates, completion state and verification notes.

Audit and risk activity

Material actions, actor details, timestamps, score changes and neutral descriptions without worker message content.

Confidential worker reports

Selected concerns, optional free text, language, time, linked workplace/site or supplier and optional image evidence.

Data subjects may include customer workspace users, supplier or site contacts entered by the customer, and workers using the confidential reporting channel. Precise categories and any special-category data handling must be completed in Annex I before execution.

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.
Organisation-scoped row policies protect cases, case events, evidence metadata, remediation, risk events, audit records and worker-access checks. Anonymous visitors have no direct table access; public pages reach data only through rate-limited server functions.
Role-based permissions inside a workspace: owner, compliance lead, investigator and read-only reviewer.
An append-only-in-practice activity record for defined material actions — including supplier changes, imports, case activity, report export and role changes. Customer users cannot update or delete entries through the application data API; activity writes are best-effort rather than a tamper-proof ledger.
Worker narratives are not surfaced in the management console, in exports or in the case layer.
Synthetic demo content is rendered from a fixed fictional dataset in the application and never written to customer data.
Worker-uploaded evidence storage access requires remediation before production evidence uploads are enabled.

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. Full-workspace deletion is handled manually on written request. Return/export, linked-record scope, backups, worker-report treatment and timing must be fixed in the signed DPA.

Incidents and cooperation

The executed DPA must define customer contacts, available information and notification timing. Cooperation with regulatory obligations and data-subject requests is subject to applicable law, the agreed scope and legal assessment; this draft promises no hour count.

Draft contractual structure

Instructions and purpose

Libera processes customer data only to provide the scoped supplier screening, worker reporting, case, remediation and documentation services, on the customer's documented instructions, except where applicable law requires otherwise.

Confidentiality

Access is limited by assigned product roles and operational need. Binding personnel confidentiality terms, access-review procedure and authorised operational roles must be confirmed in the executed agreement.

Data-subject assistance

Libera will provide reasonable product and record assistance so the customer can assess requests. Identity-minimised worker reports may be difficult to match to a requester because the report has no identity field; this limitation must be handled transparently.

Incident cooperation

The parties will define contacts, information flow and a notification window in the executed DPA. Notification and regulatory duties remain subject to applicable law and legal assessment; this template promises no fixed hour count.

Deletion or return

Supplier deletion exists in the console; full-workspace handling is manual on written request. Return/export, deletion scope, timing, backups, legal holds and worker-report treatment must be agreed. No automated retention schedule exists today.

Audit and information

Libera can provide current owner-authored security information, named infrastructure providers and relevant product records or questionnaire responses. This does not amount to a certification, independent audit, penetration test or unrestricted infrastructure inspection right.

Sub-processors

The executed DPA must list approved providers and set notice and objection terms for changes. Service regions and transfer arrangements remain to be completed; no EU-only hosting or implemented SCC mechanism is claimed here.

International transfers

Any restricted transfer must use the lawful mechanism selected after the actual hosting and processing locations are confirmed. The applicable mechanism and supplementary measures are annex placeholders, not current claims.

Outstanding before signature

Values and annexes we will not guess.

Parties, legal addresses and signatories:To be completed before execution
Subject matter, effective date and duration:To be completed before execution
Hosting region and transfer mechanism:To be completed before execution
Retention schedule per data category:To be completed before execution
Incident notification window:To be completed before execution
Security and privacy contact addresses:To be completed before execution

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Annex placeholders

• Annex I — parties, processing instructions, categories, data subjects and duration: To be completed before execution
• Annex II — verified technical and organisational measures, including current remediation: To be completed before execution
• Annex III — approved sub-processors, locations and change-notice terms: To be completed before execution
• Annex IV — restricted-transfer mechanism and supplementary measures, if applicable: To be completed before execution
• Annex V — retention, return and deletion schedule: To be completed before execution
• Annex VI — contacts, incident cooperation and audit-information process: To be completed before execution

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

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