Role split
Processing purpose
Client workflow data is processed only to provide agreed services, such as Revenue Recovery Audits, workflow diagnostics, document intake, missing-record chasing, status monitoring, workflow routing, AI-assisted drafting, audit trail creation, and reporting.
Data categories
- Accounting firm user details: name, role, work email, permissions, and activity records.
- Client workflow data: client name, entity details, job status, document names, notes, messages, checklist items, and audit history.
- Evidence metadata: source, owner, timestamp, routing decision, approval state, and escalation reason.
- Support data: error reports, configuration records, and implementation notes.
Special category data, criminal offence data, payroll details, bank details, and highly sensitive personal data should not be introduced unless explicitly agreed in writing with additional controls.
Security controls
- Least-privilege access for authorised users and implementation staff.
- Approval gates before sensitive client-facing communication is released.
- Audit trail for source, owner, timestamp, classification, decision, and approval state.
- Encryption in transit using HTTPS/TLS for production services.
- Role-based workflow access where the agreed client environment supports it.
- Separation between public demos and any agreed private client pilot environment.
- Retention, deletion, and export handled according to the signed statement of work or data processing agreement.
AI controls
- AI output is treated as a draft, classification, or recommendation, not final professional advice.
- Client-facing action should be approved, edited, or escalated by an authorised accountant.
- Risk words, unclear evidence, missing context, and advice-sensitive situations should pause for human review.
- Client data should not be used to train public models unless expressly agreed in writing.
- Model provider, retention, logging, and transfer details should be identified in the relevant client data processing agreement.
Hosting and subprocessors
Public marketing pages are hosted on Vercel. Production client workflow data should be scoped separately, including hosting region, storage location, subprocessors, backups, support access, and transfer safeguards.
Where a client requires UK or EU hosting for workflow data, that requirement should be written into the proposal, statement of work, and data processing agreement before live data is processed.
Incident handling
Suspected personal data breaches should be investigated promptly. Where The Efficiency Architects acts as processor, the accounting firm should be notified without undue delay after becoming aware of a confirmed personal data breach, with details reasonably available at the time.
Before a live pilot
- Confirm the legal contracting entity and controller/processor roles.
- Sign a data processing agreement.
- Define subprocessors, hosting region, retention, deletion, and support access.
- Define what client data is allowed into the system and what must be excluded.
- Agree approval rules, escalation rules, and who can release client-facing communication.