aiylum

Data processing addendum

The firm is the controller of its clients’ data. aiylum is a processor and acts on instruction.

Written by the team that built the product, not by outside counsel. It is an accurate description of how the system works and what we do, and you can check it against the product. It is not a lawyer’s instrument and has not been reviewed as one. If you need a signed version for a vendor review, write to legal@aiylum.com.

Status
published
Version
1.0.0
Effective
2026-09-13
Reviewed by counsel
not yet
Why this exists
GDPR Art. 28 · UK IDTA · SCCs where data leaves the EEA

This sets out how aiylum processes personal data on a firm's behalf. It supplements the terms of service and, where the two disagree about processing, this wins.

The roles

The firm is the controller of its clients' personal data. aiylum is the processor. We process only on the firm's documented instruction, and using the product is the instruction – every act the product performs is one the firm asked for by configuring or operating it.

Where we are required by law to process something the firm has not asked for, we tell them first unless the law forbids it.

Subject matter and duration

Running immigration matters: holding case files, tracking dates, exchanging messages and documents with clients, and producing work product. For as long as the firm is a customer, plus the retention window.

The people and the data

Clients of the firm, their family members where the matter involves them, and the firm's own staff. Identity and contact data, immigration history, documents, case notes, correspondence, and payment records. Frequently special category data, because asylum matters concern religion, politics, sexual orientation and health by their nature.

What we undertake

Confidentiality. Everyone with access is bound by it.

Security. Encryption in transit and at rest, per-subject key material for identifying fields, role-based access inside a firm, hard tenant separation between firms, an append-only audit ledger, scanned uploads, and regular review of all of it. The security page describes the arrangement.

Assistance. We help the firm answer data subject requests, and we help with impact assessments and regulator correspondence.

Breach notification. Without undue delay after becoming aware, with what we know at the time rather than after an investigation completes.

Deletion or return. At the end, the firm chooses. Deletion destroys the key material, which is what makes the encrypted data unrecoverable.

Audit. The firm may audit, on reasonable notice. We will answer a questionnaire, provide what documentation we have, and arrange a call with an engineer.

Sub-processors

Listed on the subprocessors page, with what each does. We give notice before the list changes, and a firm may object.

Every sub-processor is bound to terms no weaker than these, and we remain answerable to the firm for what they do.

Transfers

Data is held in the United States. Where a firm is subject to a regime that restricts transfers out of it, we will put the appropriate mechanism in place – standard contractual clauses, the UK addendum, or a data localisation arrangement – and we will say honestly whether we can support the last of those before a firm commits.

Instructions that would be unlawful

We will not follow one, and we will say why.

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*This page describes how the product is built and is written by the people who built it. It has not been reviewed by outside counsel, and it is not yet the executable addendum – ask us for the paper version before you rely on it.*

Written in English only for now. A legal document a person cannot read is one they cannot consent to, so translation is part of publishing it – not something added afterwards.