Data Processing Agreement

This agreement sets out how PharmSoft Solutions Ltd processes patient and staff personal data on behalf of a pharmacy that uses Dossette Rx Pro. It forms part of the Dossette Rx Pro subscription terms and meets the requirements of Article 28 of the UK GDPR.

1. Parties and definitions

Controller: the pharmacy business named on the subscription ("the Pharmacy").

Processor: PharmSoft Solutions Ltd ("PharmSoft"), company no. 17296407, registered office 66 Paul Street, London EC2A 4NA.

Definitions. "Data Protection Law" means the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003, as amended. "Personal Data", "Special Category Data", "Processing", "Data Subject", "Personal Data Breach" and "Sub-processor" have the meanings given in Data Protection Law. "Service" means the Dossette Rx Pro web application at dossetterxpro.com. "Pharmacy Data" means all Personal Data the Pharmacy or its staff enter into, import into or generate within the Service.

2. Roles and details of processing

The Pharmacy is the controller of Pharmacy Data and PharmSoft is its processor. PharmSoft is a separate controller only for the account and billing data it needs to run its own business, which its privacy notice covers.

Item	Detail
Subject matter	Providing the Dossette Rx Pro service for managing Monitored Dosage System (dossette box) dispensing
Nature of processing	Hosting, storage, retrieval, display, printing, structuring, backup, technical support and deletion
Purpose	Enabling the Pharmacy to schedule, prepare, record and supply medicines in MDS trays, request repeat prescriptions from GP practices and keep an audit trail of medication changes
Data subjects	Pharmacy patients receiving MDS; Pharmacy staff users; GP practice contacts (business details only)
Personal data	Patient name, date of birth, CHI/NHS number, address, phone number, GP practice, delivery or collection arrangements, hospital admission and holiday dates, notes; staff names and email addresses; audit log entries
Special category data	Health data: current medications, doses, controlled drug status, medication change history, hospital admissions
Duration	The subscription term, plus the return and deletion period in clause 9
Location	Primary database in the UK (Supabase, London region)

3. PharmSoft's obligations

PharmSoft will:

1. Process Pharmacy Data only on the Pharmacy's documented instructions, which are this agreement and the Pharmacy's use of the Service. If an instruction appears to break Data Protection Law, PharmSoft will tell the Pharmacy promptly.
2. Not use Pharmacy Data for its own purposes, sell it, share it for marketing, or use it to train any AI model.
3. Make sure anyone it authorises to access Pharmacy Data is bound by confidentiality.
4. Access Pharmacy Data only when needed to provide support, fix a fault or meet a legal duty. Support access is read-only, limited to the platform administrator and recorded in an audit log.
5. Apply the security measures in clause 4.
6. Use sub-processors only as set out in clause 5.
7. Help the Pharmacy respond to Data Subject requests (clause 7), and with DPIAs, security and breach duties, taking into account the nature of the processing.
8. Make available the information needed to show compliance with Article 28 and allow audits (clause 8).

The Pharmacy will:

1. Make sure it has a lawful basis for the processing. For patient care this will normally be Article 6(1)(e) or 6(1)(c), with Article 9(2)(h) for health data.
2. Tell patients how their data is used through its own privacy notice.
3. Manage its user accounts, keep passwords confidential and remove leavers promptly.
4. Enter only data needed for MDS dispensing.

4. Security measures

PharmSoft applies these technical and organisational measures and will not reduce their overall level during the term:

• Encryption: all traffic over HTTPS (TLS 1.2+); database encrypted at rest (AES-256) by the hosting provider.
• Tenant isolation: each pharmacy's data is separated by row-level security in the database, so one pharmacy's users cannot read another's records.
• Access control: password-protected individual accounts; authentication checked on every server request; secret keys held server-side only, never sent to the browser.
• Audit: medication changes record who made them and why; platform administrator access is logged.
• Backups: automated daily database backups retained for 7 days.
• Data minimisation: address lookups send only the postcode or address text searched; no patient data is used for analytics or advertising.
• People: PharmSoft staff with system access are bound by confidentiality and complete data protection training.

5. Sub-processors

The Pharmacy gives general authorisation for PharmSoft to use the sub-processors below. PharmSoft will give at least 30 days' notice of any new or replacement sub-processor, and the Pharmacy may object on reasonable data protection grounds. Each sub-processor is bound by written terms giving equivalent protection, and PharmSoft remains liable for them.

Sub-processor	Service	Data involved	Location
Supabase Inc.	Database, authentication, backups	All Pharmacy Data	UK (London region)
Vercel Inc.	Application hosting	Pharmacy Data in transit while pages load	UK (London, lhr1); global edge network
Resend (Plus Five Five Inc.)	Login and password-reset emails	Staff names and email addresses only	USA
Allies Computing Ltd (Postcoder)	Address lookup	Postcode or address text searched	UK

6. International transfers

Patient health data is stored in the UK. Where a sub-processor is based in or accesses data from the USA, PharmSoft relies on the UK Extension to the EU–US Data Privacy Framework where the provider is certified, or otherwise on the ICO's International Data Transfer Addendum with a transfer risk assessment.

7. Data subject requests

If PharmSoft receives a request from a patient or staff member about Pharmacy Data, it will pass it to the Pharmacy within 5 working days and not respond directly unless told to. PharmSoft will help the Pharmacy find, export, correct or delete the relevant records.

8. Personal data breaches and audits

PharmSoft will tell the Pharmacy without undue delay, and in any case within 24 hours of becoming aware, of a Personal Data Breach affecting Pharmacy Data. The notice will describe what happened, the data and patients likely affected, the likely consequences and the steps taken. The Pharmacy decides whether to notify the ICO and patients.

Once a year, or after a breach, the Pharmacy may ask for written answers on PharmSoft's compliance. An on-site or third-party audit needs 30 days' notice, takes place in business hours and is at the Pharmacy's cost.

9. Return and deletion

When the subscription ends, the Pharmacy has 30 days to export its data. PharmSoft will then delete Pharmacy Data from the live system within a further 30 days, and from backups when they expire, unless the law requires it to be kept. PharmSoft will confirm deletion in writing on request.

The Pharmacy remains responsible for keeping its own clinical and controlled drug records for the periods the law and NHS guidance require.

10. Liability and general

Each party's liability under this agreement is subject to the limits in the subscription terms. Where this agreement and the subscription terms conflict on data protection, this agreement wins. This agreement is governed by the law of England and Wales and the courts of England and Wales have exclusive jurisdiction.

Signatures

	For the Pharmacy	For PharmSoft Solutions Ltd
Name		Abbas Gulzar
Position		Director
Signature
Date