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Reviewed Jul 2026Knowledge base

Subprocessor register

Operating, reviewed on its stated cadence

Every subprocessor is enumerated with purpose, region, and data category, and the list is maintained across five named canonical copies — the engineering register, the knowledge-base article, the in-app privacy policy, the marketing assistant's corpus, and the DPA schedule a university signs — that must move together on any change. Undercounting that set is what let a copy go stale once before, so this page links to the canonical article rather than holding a sixth.

Category
Vendors
Owner
Founder
Last verified
27 July 2026
Evaluation frequency
On vendor change; full review annually

Standards mappings

This control maps to the following standards and frameworks. Each entry states our real relationship with the standard, and the specific requirements this control helps satisfy.

ISO/IEC 27001:2022InfoSec complianceSelf-assessed

A full 93-control Annex A Statement of Applicability is maintained and honestly dispositioned, and the ISMS went live on 26 July 2026 with its first completed management review. Not certified: no external audit has occurred, the clause 9.2 internal audit is openly unmet, and the certification trigger (a named tender, funding, or first hire) was formally decided at the first management review.

  • A.5.19Security in supplier relationships

Everything mapped to this standard

GDPR (EU General Data Protection Regulation)PrivacyApplicable law

Applies via international students. The 72-hour breach path is in the incident runbook, Article 28 processor terms sit in the counsel-approved DPA, Article 17 erasure maps to the student's own hard-delete cascade (with the audit-trail carve-out disclosed rather than hidden), and Article 22-equivalent disclosure covers automated crisis detection.

  • Art. 28Processor obligations

Everything mapped to this standard

Australian Privacy Act 1988 (APPs, incl. the NDB scheme)PrivacyApplicable law

The primary legal regime. APP 8 drives the residency objective and every disclosed cross-border flow, APP 11 drives retention and erasure, and the Notifiable Data Breaches scheme's assessment clock is built into the incident runbook with OAIC contacts documented. The privacy policy, terms, and DPA template are counsel-reviewed and approved.

  • APP 8Cross-border disclosure of personal information

Everything mapped to this standard

Policy mapping

The written standard this control enforces:

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