This general Data Processing Addendum page describes baseline data processing concepts for relationships where ICM / GLC processes data on behalf of a client, collaborator, learner, organization, or regulated workflow. Specific terms may require a signed agreement.
Roles
Depending on the service, a client or participating organization may act as controller, business, covered entity, customer, school, research group, or similar role, and ICM / GLC may act as processor, service provider, vendor, contractor, records steward, platform operator, or similar role. Applicable jurisdiction-specific terminology and obligations are handled in the written agreement for the service relationship.
Processing
- Processing is limited to providing, securing, supporting, documenting, and improving contracted services.
- Subprocessors or infrastructure providers may be used where needed to operate services.
- Deletion, export, return, or restriction requests may be submitted through Support and handled subject to legal, security, backup, and contractual limits.
- Security measures are applied based on service scope, data sensitivity, and written agreement terms.
DPA requests may be routed through this site’s Contact or Support page before regulated, client-controlled, or contract-specific data-processing workflows begin.