Data Processing Addendum (Zero-Data Retention Standard)

Effective Date: October 2026

Between: FiduOS ("Data Processor") and the User Law Firm ("Data Controller")

  1. Scope and Regulatory Intent: This Addendum governs the processing of personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in connection with estate schedule extraction services.
  2. Processing Purpose & Nature: The Processor processes estate financial documentation solely to transcribe, format, and aggregate line items for statutory HMRC inheritance tax reporting schedules (including IHT400, IHT406, IHT411, IHT409, and IHT419).
  3. Zero-Data Retention (ZDR) Architecture:
    • The Processor operates on an ephemeral, stateless execution environment hosted exclusively within the UK (London) region.
    • Ingestion, optical character parsing, and schedule calculations are executed exclusively within volatile in-memory runtime instances.
    • All uploaded source files, raw text extracts, and interim structures are irreversibly purged upon transmission of the output ZIP bundle or browser session termination. No persistent disk writes, customer databases, or model training occur.
  4. Sub-processors & Confidentiality: Ephemeral API inference partners are bound by strict enterprise confidentiality and zero-data training covenants. All data in transit is encrypted using TLS 1.3.
  5. Audit Rights & Regulatory Supervisory Compliance (SRA & LLS): The Processor generates an immutable, timestamped verification certificate per processed file (SRA/LLS Audit Certificate pdf) to substantiate human oversight and fulfill the Controller’s regulatory supervisory requirements.