The sub-processors we use are listed on our sub-processors page.
Version 1.0 | Effective from 21 October 2026
(1) The Customer: the professional, practice or organisation that holds a PlanProve account and has accepted this Agreement (the Data Controller).
(2) Make My Plan Ltd, trading as "PlanProve", incorporated and registered in England and Wales with company number 16887298, whose registered office is at 22a Ashton Road, Bristol, BS3 2EA (the Data Processor).
This Data Processing Agreement (the Agreement) sets out the additional terms, requirements and conditions on which the Data Processor will process Personal Data when providing services under the Principal Agreement. This Agreement contains the mandatory clauses required by Article 28(3) of the UK General Data Protection Regulation for contracts between controllers and processors.
The Principal Agreement is the PlanProve Terms of Service at planprove.com/terms. This Agreement forms part of the Principal Agreement and takes effect when the Customer accepts it.
1.1 The following definitions and rules of interpretation apply in this Agreement.
1.2 This Agreement is subject to the terms of the Principal Agreement and is incorporated into the Principal Agreement. Interpretations and defined terms set forth in the Principal Agreement apply to the interpretation of this Agreement.
1.3 The Annexes form part of this Agreement and will have effect as if set out in full in the body of this Agreement. Any reference to this Agreement includes the Annexes.
1.4 A reference to writing or written includes email.
1.5 In the case of conflict or ambiguity between:
a) any provision contained in the body of this Agreement and any provision contained in the Annexes, the provision in the body of this Agreement will prevail;
b) the terms of any accompanying invoice or other documents annexed to this Agreement and any provision contained in the Annexes, the provision contained in the Annexes will prevail; and
c) any of the provisions of this Agreement and the provisions of the Principal Agreement, the provisions of this Agreement will prevail.
The Data Controller and the Data Processor agree and acknowledge that for the purpose of the Data Protection Legislation:
a) the Data Controller is the Controller, and the Data Processor is the Processor;
b) the Data Controller retains control of the Personal Data and remains responsible for its compliance obligations under the Data Protection Legislation, including but not limited to, providing any required notices, and obtaining any required consents, and for the written processing instructions it gives to the Data Processor; and
c) Annex A describes the subject matter, duration, nature and purpose of the processing and the Personal Data categories and Data Subject types in respect of which the Data Processor may process the Personal Data to fulfil the Business Purposes.
3.1 The Data Processor will only process the Personal Data to the extent, and in such a manner, as is necessary for the Business Purposes in accordance with the Data Controller's written instructions. The Data Processor will not process the Personal Data for any other purpose or in a way that does not comply with this Agreement or the Data Protection Legislation. The Data Processor must promptly notify the Data Controller if, in its opinion, the Data Controller's instructions do not comply with the Data Protection Legislation.
3.2 The Data Processor must comply promptly with any Data Controller written instructions requiring the Data Processor to amend, transfer, delete or otherwise process the Personal Data, or to stop, mitigate or remedy any unauthorised processing.
3.3 The Data Processor will maintain the confidentiality of the Personal Data and will not disclose the Personal Data to third parties unless the Data Controller or this Agreement specifically authorises the disclosure, or as required by domestic or EU law, court, or regulator (including the Commissioner). If a domestic or EU law, court, or regulator (including the Commissioner) requires the Data Processor to process or disclose the Personal Data to a third party, the Data Processor must first inform the Data Controller of such legal or regulatory requirement and give the Data Controller an opportunity to object or challenge the requirement, unless the domestic or EU law prohibits the giving of such notice.
3.4 The Data Processor will reasonably assist the Data Controller, at no additional cost to the Data Controller, with meeting the Data Controller's compliance obligations under the Data Protection Legislation, taking into account the nature of the Data Processor's processing and the information available to the Data Processor, including in relation to Data Subject rights, data protection impact assessments and reporting to and consulting with the Commissioner under the Data Protection Legislation.
3.5 The Data Processor must notify the Data Controller promptly of any changes to the Data Protection Legislation that may reasonably be interpreted as adversely affecting the Data Processor's performance of the Principal Agreement or this Agreement.
4.1 The Data Processor will ensure that all of its employees:
a) are informed of the confidential nature of the Personal Data and are bound by written confidentiality obligations and use restrictions in respect of the Personal Data;
b) have undertaken training on the Data Protection Legislation and how it relates to their handling of the Personal Data and how it applies to their particular duties; and
c) are aware of both the Data Processor's duties and their personal duties and obligations under the Data Protection Legislation and this Agreement.
5.1 The Data Processor must always implement appropriate technical and organisational measures against accidental, unauthorised, or unlawful processing, access, copying, modification, reproduction, display, or distribution of the Personal Data, and against accidental or unlawful loss, destruction, alteration, disclosure, or damage of Personal Data including, but not limited to, the security measures set out in Annex B.
5.2 The Data Processor must implement such measures to ensure a level of security appropriate to the risk involved, including as appropriate:
a) the pseudonymisation and encryption of personal data;
b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
d) a process for regularly testing, assessing, and evaluating the effectiveness of the security measures.
6.1 The Data Processor will notify the Data Controller in writing without undue delay and, where feasible, within 72 hours after becoming aware of:
a) the loss, unintended destruction or damage, corruption, or unsuitability of part or all of the Personal Data. The Data Processor will restore such Personal Data at its own expense as soon as possible;
b) any accidental, unauthorised, or unlawful processing of the Personal Data; or
c) any Personal Data Breach.
6.2 Where the Data Processor becomes aware of (a), (b) or (c) above, it will provide the Data Controller with the following written information, without undue delay and in phases where it is not all available at the same time:
a) a description of the nature of (a), (b) or (c), including the categories of in-scope Personal Data and approximate number of both Data Subjects and the Personal Data records concerned;
b) the likely consequences; and
c) a description of the measures taken or proposed to be taken to address (a), (b) or (c), including measures to mitigate its possible adverse effects.
6.3 Immediately following any accidental, unauthorised, or unlawful Personal Data processing or Personal Data Breach, the parties will co-ordinate with each other to investigate the matter. Further, the Data Processor will reasonably co-operate with the Data Controller at no additional cost to the Data Controller, in the Data Controller's handling of the matter, including but not limited to:
a) assisting with any investigation;
b) making available all relevant records, logs, files, data reporting and other materials required to comply with all Data Protection Legislation or as otherwise reasonably required by the Data Controller;
c) taking reasonable and prompt steps to mitigate the effects and to minimise any damage resulting from the Personal Data Breach or accidental, unauthorised, or unlawful Personal Data processing; and
d) not informing any third party of any accidental, unauthorised, or unlawful processing of all or part of the Personal Data and/or a Personal Data Breach without first obtaining the Data Controller's written consent, except when required to do so by domestic law.
6.4 The Data Processor agrees that the Data Controller has the sole right to determine:
a) whether to provide notice of the accidental, unauthorised, or unlawful processing and/or the Personal Data Breach to any Data Subjects, the Commissioner, other in-scope regulators, law enforcement agencies or others, as required by law or regulation or in the Data Controller's discretion, including the contents and delivery method of the notice; and
b) whether to offer any type of remedy to affected Data Subjects, including the nature and extent of such remedy.
6.5 Subject to clause 15.2, the Data Processor will cover all reasonable expenses associated with the performance of the obligations under 6.1 to 6.4 unless the matter arose from the Data Controller's specific written instructions, negligence, wilful default, or breach of this Agreement, in which case the Data Controller will cover all reasonable expenses.
6.6 Subject to clause 15.2, the Data Processor will also reimburse the Data Controller for actual reasonable expenses that the Data Controller incurs when responding to an incident of accidental, unauthorised, or unlawful processing and/or a Personal Data Breach to the extent that the Data Processor caused such, including all costs of notice and any remedy as set out in 6.4.
7.1 The Data Processor shall not transfer or permit the transfer of Personal Data originating from the UK or EEA to any country outside the UK or EEA unless such transfer strictly complies with Chapter V of the UK GDPR (and EU GDPR, where applicable).
7.2 For sub-processors located in the United States that maintain an active certification under the EU-US Data Privacy Framework (DPF) and the UK Extension to the EU-US DPF (UK-US Data Bridge), transfers shall rely on UK Adequacy as the primary legal mechanism under Section 17A of the Data Protection Act 2018.
7.3 Where an adequacy decision or DPF certification does not apply, or operates as a contractual backstop, restricted transfers to sub-processors are governed by EU Standard Contractual Clauses, specifically the UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (issued by the ICO under Section 119A of the DPA 2018), which modifies Module 3 of the EU SCCs (2021 EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914)) for UK data transfers. The Data Processor has entered into an agreement with each sub-processor that provides data protection terms equivalent in substance to those set out in this Agreement.
8.1 The Data Processor may only authorise a third party (sub-processor) to process the Personal Data if:
a) the Data Controller provides general written authorisation for the appointment of sub-processors, and the Data Processor provides the Data Controller with at least fourteen (14) days' prior written notice of any intended addition or replacement of a sub-processor, thereby giving the Data Controller the opportunity to object to such change prior to the engagement of the sub-processor;
b) the Data Processor enters into a written contract with the sub-processor that contains data protection terms equivalent in substance to those set out in this Agreement, in particular, in relation to requiring appropriate technical and organisational data security measures, and, upon the Data Controller's written request, provides the Data Controller with copies of the relevant excerpts from such contracts; and
c) the Data Processor maintains control over all of the Personal Data it entrusts to the sub-processor.
8.2 Those sub-processors approved as at the commencement of this Agreement are set out in Annex A. If the Data Controller does not object in writing to a proposed sub-processor within fourteen (14) days of receiving notice pursuant to clause 8.1(a), the sub-processor shall be deemed approved, and Annex A shall be updated accordingly.
8.3 If the Data Controller objects in writing on reasonable data protection grounds within that period and the parties cannot resolve the objection within fourteen (14) days of it being raised, the Data Controller may end the affected services by written notice, and the Data Processor will refund prepaid fees for the period after the services end.
8.4 Where a sub-processor must be replaced urgently to maintain security or continuity of the service, the Data Processor may do so immediately and will notify the Data Controller as soon as reasonably practicable. The right to object in clauses 8.2 and 8.3 applies from the date of that notice.
8.5 Notice under this clause 8 will be given by email to the email address on the Data Controller's account, and Annex A will be kept up to date at planprove.com/sub-processors.
8.6 Where the sub-processor fails to fulfil its obligations under the written agreement with the Data Processor, the Data Processor remains fully liable to the Data Controller for the sub-processor's performance of its agreement obligations.
8.7 The Parties agree that the Data Processor will be deemed by them to legally control any Personal Data controlled practically by or in the possession of its sub-processors.
9.1 The Data Processor must, at no additional cost to the Data Controller, take such technical and organisational measures as may be appropriate, and promptly provide such information to the Data Controller as the Data Controller may reasonably require, to enable the Data Controller to comply with:
a) the rights of Data Subjects under the Data Protection Legislation, including, but not limited to, subject access rights, the rights to rectify, port and erase personal data, object to the processing and automated processing of personal data, and restrict the processing of personal data; and
b) information or assessment notices served on the Data Controller by the Commissioner or other relevant regulator under the Data Protection Legislation.
9.2 The Data Processor must notify the Data Controller immediately in writing if it receives any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Data or to either party's compliance with the Data Protection Legislation.
9.3 The Data Processor must notify the Data Controller immediately if it receives a request from a Data Subject for access to their Personal Data or to exercise any of their other rights under the Data Protection Legislation.
9.4 The Data Processor will give the Data Controller, at no additional cost to the Data Controller, its full co-operation and assistance in responding to any complaint, notice, communication, or Data Subject request.
9.5 The Data Processor must not disclose the Personal Data to any Data Subject or to a third party other than in accordance with the Data Controller's written instructions, or as required by domestic or EU law.
10.1 This Agreement will remain in full force and effect so long as:
a) the Principal Agreement remains in effect; or
b) the Data Processor retains any of the Personal Data related to the Principal Agreement in its possession or control (the Term).
10.2 Any provision of this Agreement that expressly or by implication should come into or continue in force on or after termination of the Principal Agreement in order to protect the Personal Data will remain in full force and effect.
10.3 The Data Processor's failure to comply with the terms of this Agreement is a material breach of the Principal Agreement. In such event, the Data Controller may terminate the Principal Agreement.
10.4 If a change in any Data Protection Legislation prevents either party from fulfilling all or part of its Principal Agreement obligations, the parties may agree to suspend the processing of the Personal Data until that processing complies with the new requirements. If the parties are unable to bring the Personal Data processing into compliance with the Data Protection Legislation within 30 days, either party may terminate the Principal Agreement on not less than 30 days' written notice to the other party.
11.1 At the Data Controller's request, the Data Processor will give the Data Controller, or a third party nominated in writing by the Data Controller, a copy of or access to all or part of the Personal Data in its possession or control in the format and on the media reasonably specified by the Data Controller.
11.2 On termination of the Principal Agreement for any reason or expiry of its term, the Data Processor will securely delete or destroy or, if directed in writing by the Data Controller, return and not retain, all or any of the Personal Data related to this Agreement in its possession or control.
11.3 If any law, regulation, or government or regulatory body requires the Data Processor to retain any documents, materials or Personal Data that the Data Processor would otherwise be required to return or destroy, it will notify the Data Controller in writing of that retention requirement, giving details of the documents, materials or Personal Data that it must retain, the legal basis for such retention, and establishing a specific timeline for deletion or destruction once the retention requirement ends.
11.4 On the Data Controller's written request, the Data Processor will certify in writing that it has deleted or destroyed the Personal Data within 30 days after it completes the deletion or destruction.
The Data Processor will keep detailed, accurate and up-to-date written records regarding any processing of the Personal Data, including but not limited to, the access, control and security of the Personal Data, approved sub-processors, the processing purposes, categories of processing, and a general description of the technical and organisational security measures referred to in clause 5.1 (Records).
a) The Data Processor will ensure that the Records are sufficient to enable the Data Controller to verify the Data Processor's compliance with its obligations under this Agreement and the Data Protection Legislation and the Data Processor will provide the Data Controller with copies of the Records upon request.
b) The Data Controller and the Data Processor must review the information listed in the Annexes to this Agreement at least once a year to confirm its current accuracy and update it when required to reflect current practices.
13.1 The Data Processor shall make available to the Data Controller all information reasonably necessary to demonstrate compliance with the law. To satisfy this requirement, the Data Processor shall, upon written request (and no more than once per 12-month period), provide the Data Controller with summaries of its most recent compliance documentation and, where available, third-party security assessments and executive summaries of external network penetration tests.
13.2 The Data Controller (or its independent, accredited third-party auditor bound by strict confidentiality) may only conduct an audit of the Data Processor's operations if:
a) the documentation provided under 13.1 is demonstrably insufficient to confirm compliance;
b) a confirmed Personal Data Breach has occurred attributable to the Data Processor; or
c) an audit is explicitly mandated by a competent data protection authority.
13.3 Any audit conducted under clause 13.2 shall be subject to the following conditions:
a) conducted during normal business hours upon at least thirty (30) business days' prior written notice (except in the event of an active, confirmed Personal Data Breach);
b) audits shall not grant access to raw production databases, proprietary code, or systems containing the data of the Data Processor's other clients; and
c) the Data Controller shall bear all costs incurred by it and its auditors. Furthermore, the Data Controller shall reimburse the Data Processor for all reasonable time and resources expended in supporting the audit at the Data Processor's standard professional services rates, unless the audit reveals a material breach of this Agreement by the Data Processor.
14.1 The Data Processor warrants and represents that:
a) its employees accessing the Personal Data on its behalf are reliable and trustworthy and have received the required training on the Data Protection Legislation;
b) it and anyone operating on its behalf will enter agreements to require that Personal Data will be processed in compliance with the Data Protection Legislation and other laws, enactments, regulations, orders, standards, and other similar instruments;
c) it has no reason to believe that the Data Protection Legislation prevents it from providing any of the Principal Agreement's contracted services; and
d) considering the current technology environment and implementation costs, it will take appropriate technical and organisational measures to prevent the accidental, unauthorised, or unlawful processing of Personal Data and the loss or damage to the Personal Data, and ensure a level of security appropriate to:
i. the harm that might result from such accidental, unauthorised, or unlawful processing and loss or damage;
ii. the nature of the personal data protected; and
iii. compliance with all applicable data protection legislation and its information and security policies, including the security measures required in 5.1.
14.2 The Data Controller warrants and represents that the Data Processor's expected use of the Personal Data for the Business Purposes and as specifically instructed by the Data Controller will comply with the Data Protection Legislation.
15.1 The Data Processor shall be liable to the Data Controller for direct losses, damages, and reasonable costs incurred by the Data Controller arising directly from a material breach by the Data Processor (or its sub-processors) of its obligations under this Agreement or Data Protection Legislation. The Data Processor shall not be liable for incidental or indirect losses, such as loss of profits, business, or reputational damage. The Data Processor shall not be liable where any breach or failure arises from the Data Controller's instructions, negligence, or breach of Data Protection Legislation.
15.2 Each party's total liability arising out of or in connection with this Data Processing Agreement shall be strictly subject to the limitations and exclusions of liability set out in the Principal Agreement.
16.1 Any notice or other communication given to a party under or in connection with this Agreement must be in writing and delivered to:
16.2 Clause 16.1 does not apply to the service of any proceedings or other documents in any legal action or, where applicable, any arbitration or other method of dispute resolution.
16.3 This Agreement is governed by the law, and is subject to the jurisdiction, stated in the Principal Agreement (England and Wales).
16.4 This Agreement takes effect when the Data Controller accepts it and continues as set out in clause 10.
Subject matter of processing: The provision of PlanProve Customer Relationship Management (CRM) and casework platform by the Data Processor for the Data Controller, including cloud database management, document hosting, tools, and optional AI-assisted functions.
Duration of processing: For the term of the Principal Agreement, remaining active throughout the Data Controller's operational use of the platform and extending for a reasonable period following termination until the deletion or return of all Personal Data in accordance with this Agreement.
Nature of processing: As required for CRM and casework processing, including the ingestion, storage, and organisation of personal data, and the linking of data with client records, site data, and correspondence within the platform. The CRM also enables financial document generation (fee proposals and invoicing), allows for project file hosting, communications, and optional AI-assisted data extraction and analysis when enabled by the Controller.
Business purposes: To enable the Data Controller to manage planning applications and related casework. Processing primarily includes client administration and contact management. This includes tracking task assignment and providing workflow oversight. It also includes commercial correspondence (such as fee proposals and standard terms and conditions), managing financial operations (such as hourly rate calculations, invoicing, and billing records), and providing the corresponding secure cloud hosting and storage for user-uploaded project documents within the platform.
Personal data categories:
Data subject types:
Special Category Data is not intentionally required or collected for the standard operational use of the platform. The Data Controller retains sole responsibility for ensuring that Special Category Data (such as health information, accessibility requirements, or religious beliefs) is not entered into the platform, including in free-text fields or document uploads, unless a valid lawful basis and Article 9 processing condition under the UK GDPR have been satisfied prior to input.
Authorised persons:
Approved sub-processors:
| Sub-processor | Purpose | Location | Transfer mechanism |
|---|---|---|---|
| Supabase Inc. | Database and file storage | Ireland, EU-west-1 | Adequacy |
| Anthropic PBC | AI Planning Assistant and document extraction (in-product features); and AI-assisted development, debugging, and administrative support tooling. | USA | UK Addendum to EU SCCs |
| Stripe Inc. | Payment processing for invoices paid through the platform (Stripe Connect). PlanProve does not store card details. | USA | UK Addendum to EU SCCs/DPF |
| Resend Inc. | Transactional email delivery | USA | UK Addendum to EU SCCs/DPF |
| Vercel Inc. | Application hosting. Application functions run in the UK and EU (London eu-west-2, Dublin eu-west-1, Paris eu-west-3). Request routing runs on Vercel's global edge network. | UK/EU for functions, global for edge routing | UK Addendum to EU SCCs/DPF |
| PostHog Inc. | Product analytics | EU (Frankfurt eu-central-1) | Adequacy |
| Cloudflare Inc. | Storage backup (R2) | EU | Adequacy |
Data encryption and technical security
All web traffic, user connections, and external API communications are encrypted in transit using HTTPS with Transport Layer Security (TLS 1.2 or higher).
All Personal Data and uploaded files stored within database infrastructure are encrypted at rest using Advanced Encryption Standard (AES-256), enforced at the database layer via Supabase.
Access control and authentication
Platform access requires unique individual credentials (email and password). Multi-Factor Authentication (MFA) utilising Time-based One-Time Password (TOTP) protocols is supported.
Practice administrators may restrict which team members can access individual sites and their casework.
Security audits and AI
Upon the Data Controller's written request, the Data Processor shall make available summaries of any security audits and penetration tests it has commissioned, where available.
There are currently no active native software integrations with external tools (other than the sub-processors listed in the Agreement). All processing executed using AI tools will be governed by commercial terms that explicitly prohibit the use of customer data to train or improve AI models.
Business continuity and incident management
Database backups and infrastructure disaster recovery are managed directly by cloud hosting provider Supabase under their standard platform service terms. Uploaded documents and files are separately backed up daily to Cloudflare R2, independent of the primary database infrastructure.
While fixed contractual Service Level Agreements (SLAs) are not provided for application downtime, software defects and security incidents are classified as critical priorities and addressed with urgent remediation procedures.
Data rights and retention
The platform has native export tools and rights management tools, allowing authorised users to generate and download JSON (and attachments in original format) datasets to satisfy requests and delete data as necessary.
Account deletion for professional and practice accounts is processed manually by the Data Processor on request. All personal data residing on production databases shall be deleted in accordance with the terms of this agreement. Residual data stored on automated database backups is fully overwritten within 7 days of deletion from the production environment. Residual data stored in automated document/file storage backups is fully overwritten within 30 days of deletion.