This page is for HR, IT and data protection teams who need to understand what happens if files are submitted for classification, redaction or response preparation.
It describes our processing. It is not itself a signed Data Processing Agreement. A DPA can be provided on request for a paid processing engagement.
1. Roles
| Party | Role |
|---|---|
| Your organisation | Controller of employee and third-party personal data in the files |
| Pilbeam & Co. Ltd (DSAR.uk) | Processor of files you submit for classification, redaction or bundling |
Free local search is designed so original files stay in your environment. We do not receive that file set unless you later submit it.
Website and triage data, where we act as controller, is covered by the Privacy Policy.
2. What we process
Only data you submit, which may include:
- Documents, PDFs, spreadsheets and presentations
- Exported email and Teams data, including Microsoft 365 exports
- Names, contact details, HR and employment content, and third-party data inside those files
- Processing logs, classification labels, redaction marks and evidence packages we generate for you
We process this only to provide the Services you request: classification, redaction, conversion to searchable PDFs, response bundling, and related support.
3. Your instructions
By submitting files and selecting processing stages, you instruct us to process that data for those stages. You must have a lawful basis and authority to instruct us.
4. Security measures
Consistent with the product description:
- You choose which data is submitted
- Data is protected during transfer and processing
- Access is restricted to authorised personnel
- Processing activity is recorded
- Original and processed versions are kept separate
- Unnecessary metadata is excluded from disclosure PDFs where the product does so
- Retention and deletion follow the policy below
Further technical detail can be provided during triage or a paid engagement.
5. Subprocessors
We use service providers to host systems, deliver email and operate the Services. We do not use a subprocessor to process submitted DSAR files except as needed to deliver those Services, under written terms requiring appropriate protection.
A current list of subprocessors used for a particular engagement is available on request.
6. International transfers
Where personal data is transferred outside the UK, we use appropriate safeguards required by UK data protection law. Confirm the hosting location for your engagement with us before submitting files if that is a requirement for your organisation.
7. Retention and deletion
Submitted files are kept only for the engagement. Generated outputs, such as redacted PDFs and evidence packages, are made available for you to download. Copies we still hold are deleted after the engagement unless you ask us to retain them, or we must retain them by law or to defend a claim.
Security and audit logs may be retained for a limited period after the engagement ends.
8. Assistance
We will, as reasonably possible given the nature of the processing, assist you with security, breach notification, and data-subject or ICO requests that relate to data we process for you. You remain responsible for the DSAR response to the employee.
9. Breach notification
We will notify you without undue delay if we become aware of a personal data breach affecting data we process for you.
10. Return and deletion
When the engagement ends, you may request return or deletion of submitted files and outputs we still hold, except where we must retain them by law.
11. Contact
Questions about security or data handling can be raised through the triage form, including before any files are submitted.