02 / Privacy & data governance

Clarity over whose data it is, why it is used and where it goes.

Trustworthy data handling begins with an explicit processing purpose, defined roles, documented retention decisions and an understandable path for people to exercise their privacy rights.

Context and scope

What this means
in an enterprise review.

Numerish can act in different processing roles. Information gathered for its own website, commerce or account administration differs from customer-managed employee, client, project or operational data held inside a subscribed tenant.

The descriptions below outline control expectations and evidence to evaluate. They do not claim that a specific Numerish product has completed independent certification.

Control objectives

The six areas
to assess.

Each domain brings a specific objective and a practical review item. Choose the level of assurance needed for the relevant service and regulatory context.

DOMAINCONTROL OBJECTIVEREVIEW EVIDENCE
01

Controller, processor & customer responsibilities

Identify the entity determining each processing purpose and who receives and fulfils rights requests. Customer records must not be confused with Numerish’s own account and security records.

Request or inspect

Entity and processing-role map, signed DPA and customer instruction boundaries.

02

Data lifecycle and minimisation

Assess collection, use, sharing, access, storage, archiving and deletion by information class. A retention rule needs an actual business and statutory basis.

Request or inspect

Data-category inventory, retention schedule, deletion procedures and legal-hold exceptions.

03

Residency & transfers

Understand storage location, support access, backup locations and transfers involving subprocessors; configuration can differ by service or sovereign deployment.

Request or inspect

Region and subprocessor schedules, transfer mechanisms, support-access locations and residency exceptions.

04

Consent & privacy choices

Separate service notices from optional analytics, marketing and other consent-dependent activities. Consent evidence and withdrawal controls must be context-appropriate.

Request or inspect

Consent policy, preference management test, notice versions and withdrawal event logs.

05

Rights and complaints

Support authenticated requests for access, correction, deletion, restriction, portability or objection when applicable, while avoiding disclosures to unauthorised requesters.

Request or inspect

Request-intake workflow, verification protocol, processing timeline and escalation path.

06

AI and data disclosures

Determine whether AI features transmit content to an external provider, what is logged, which contractual rights apply and whether the feature can be disabled by policy.

Request or inspect

AI data-flow map, provider terms, purpose limitations, logging and tenant-control evidence.

Responsibility & acceptance

Clear ownership.
Clear evidence.

The dividing line between supplier capability and customer responsibilities should be agreed before implementation or procurement sign-off.

Numerish / subject to product scope

What Numerish should demonstrate

  • 01Controller, processor & customer responsibilitiesEntity and processing-role map, signed DPA and customer instruction boundaries.
  • 02Data lifecycle and minimisationData-category inventory, retention schedule, deletion procedures and legal-hold exceptions.
  • 03Residency & transfersRegion and subprocessor schedules, transfer mechanisms, support-access locations and residency exceptions.
  • 04Consent & privacy choicesConsent policy, preference management test, notice versions and withdrawal event logs.
  • 05Rights and complaintsRequest-intake workflow, verification protocol, processing timeline and escalation path.
  • 06AI and data disclosuresAI data-flow map, provider terms, purpose limitations, logging and tenant-control evidence.
Customer / governed administration

Your organisation remains responsible for

  1. Specify lawful processing purposes for customer-controlled records.
  2. Set retention, privacy and access policies for your organisation.
  3. Verify international transfer and country-specific requirements.
  4. Report rights requests and privacy incidents through designated channels.
Scope boundary

Privacy commitments depend on applicable law, the selected Numerish services, the actual responsible entity and contracted data-processing arrangements.

Assurance engagement

Validate the controls
for your environment.

Request product- and version-specific artefacts; identify the relevant jurisdiction, data classes, hosting model and procurement requirements.

Request relevant evidence ↗Documents may be subject to availability, authorisation and confidentiality requirements.
Frequently asked

Important clarifications.

Controls and independently verified outcomes should not be confused.

Can customers select where their data resides?

Some deployment offerings may support regional or sovereign controls, but no universal region selection is promised. Confirm the supported locations and transfers in the order and data-processing terms.

Is the public Privacy Policy the same as a DPA?

No. The public notice describes general processing. A data processing agreement can define customer-controller and supplier-processor duties for contracted services.