§ 06Privacy & Digital TrustGlobal

Data Processing and Subprocessor Statement

How we act as a controller and processor, and the sub-processors we rely on to operate.

Effective 1 January 2026
Review 1 January 2027
Version 1.0
2 min read
Privacy & Digital TrustGlobal
01

Our roles

TD & Partners Global acts as a data controller for information collected through our website, enquiries, recruitment and our own operations. Where we deliver services to a client that involve processing the client's personal data on the client's instructions, we generally act as a data processor under a written agreement that sets out our obligations.

02

Controller responsibilities

As a controller, we determine the purposes and means of processing our own personal data and comply with applicable data-protection law, as described in our Global Privacy Notice. We are accountable for that processing and for responding to individuals' requests where we are the controller.

03

Processor responsibilities

As a processor, we process personal data only on the documented instructions of the client, under a contract that meets applicable legal requirements. We do not use client personal data for our own purposes and we assist clients in meeting their obligations where agreed.

04

Sub-processors

We rely on sub-processors to help us operate our website, host systems, provide security, and deliver services. We engage sub-processors under contracts that require appropriate confidentiality, security and compliance with data-protection law. We limit sub-processor access to what is necessary.

05

Categories of sub-processor

Principal categories include website hosting and infrastructure, analytics (where consented), form and content management, email and communications, and security tooling. Specific providers may change over time; we maintain an internal register and will provide reasonable information on request.

06

International transfers

Where sub-processors transfer personal information internationally, we rely on appropriate safeguards such as standard contractual clauses or other lawful mechanisms. We assess transfers to ensure they provide a level of protection appropriate to the information.

07

Security measures

We require sub-processors to maintain appropriate technical and organisational measures, as described in our Information Security Statement. We assess sub-processors before engagement and review them periodically where appropriate.

08

Changes to sub-processors

Where we add or replace sub-processors that process client personal data, we follow the notice and objection provisions in the relevant client agreement. For our own processing, we update this statement where material.

09

Review

We review this statement regularly and update it when our processing arrangements change materially. The effective date and version are shown on the policy page.

About this document

This policy is published by TD & Partners Global. It applies across our operations in Zimbabwe and the United Kingdom unless a specific jurisdiction is stated.

Legal entity information

The registered legal entity details for each jurisdiction are confirmed on request and published here once formally verified. We do not display unverified registration information.

Concerns or requests relating to this policy

privacy@tdpartnersglobal.com
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