Supplier Data Processing Contract Audit

Date of Audit: 06/04/2026 Auditor: Dr Serena Haywood (SIRO) Scope: All third-party suppliers identified in the Supplier Register that handle Personal Identifiable Information (PII).

1. Audit Summary

Metric Value
Total Suppliers Handling PII 3
Total with Compliant Security Clauses 3
Compliance Percentage 100%

2. Detailed Verification

Supplier Data Category Clause Mechanism Article 28 Verified?
Northflank Patient/Application Data Northflank Data Processing Agreement Yes
Microsoft 365 (Exchange Online) User Contact Data (Email Metadata) Microsoft Online Services Data Protection Addendum (DPA) Yes
GitHub Developer Account Data GitHub Global Data Protection Agreement Yes

3. Mandatory Clause Checklist

Each contract listed above has been verified to contain the following mandatory security requirements:

  • Security Measures: Obligation to implement appropriate technical and organisational measures (e.g. encryption, access controls, MFA).
  • Breach Notification: Requirement to notify CheckTick without undue delay after becoming aware of a personal data breach.
  • Sub-processing: Controls governing the use of sub-processors, including transparency and contractual flow-down of obligations.
  • Audit Rights: Provision for CheckTick (or reliance on independent third-party audits such as ISO 27001/SOC 2 reports) to verify compliance.

4. Scope Clarification

Proton Mail is used for corporate communications only and does not process personal data related to health or care services. It is therefore ุฎุงุฑุฌ the scope of this audit.

Namecheap does not process personal data on behalf of CheckTick and is also ุฎุงุฑุฌ scope.

5. Conclusion

As of the date of this audit, 100% of suppliers handling personal data on behalf of CheckTick are under contract with terms that meet or exceed UK GDPR Article 28 requirements and ICO guidance.

No new supplier may be onboarded to process personal data without the SIRO first verifying the presence of appropriate data processing terms.