Sub-Processor Register

Article 28 UK GDPR & EU GDPR

Last Updated: July 8th, 2026


Introduction

This register is the authoritative list of all sub-processors engaged by DAN to process personal data (including patient special category data) on behalf of dental practices.

It is incorporated by reference into Schedule 2 of the DAN Practice Data Processing Agreement (DPA) and into Section 3 of the DAN Records of Processing Activities (RoPA).

The current version is always available at https://dentalaudionotes.com/app/privacy.

1. Register Details

Field Detail
Organisation Dental Audio Notes Ltd (DAN)
Register owner DAN Data Protection Officer
Version 1.0
Effective date 10 June 2026
Published at https://dentalaudionotes.com/app/privacy
Incorporated into DAN Practice DPA — Schedule 2 (by reference);

DAN RoPA — Section 3 (by reference)

Notice period for changes 30 days' written notice to practices before adding or changing any sub-processor (Practice DPA clause 5.2)
Next review due 10 June 2027

2. Authorised Sub-Processors

2.1 Amazon Web Services (AWS)

Sub-Processor Amazon Web Services (AWS)
Role Cloud infrastructure and AI processing
Status Active
Location UK: eu-west-2 (London);

EU: eu-west-3 (Paris);

Service Provided Cloud infrastructure: compute (EC2), storage (S3), AI processing (Bedrock), transactional email delivery (Simple Email Service – SES).
Data Processed All patient and end user data stored and processed within DAN's AWS environment. Clinical records stored as encrypted objects in S3. End user (clinician) email addresses and transactional email content (e.g. account notifications, password resets) processed via AWS SES within the same AWS environment.
Safeguards AWS GDPR DPA in place.

SOC 2 Type 2;

ISO 27001 certified.

Patient data does not leave DAN's VPC for Bedrock processing.

AWS confirmed: no customer data used for Bedrock model training.

Agreement in Place AWS Customer Agreement

AWS GDPR DPA (automatic, download and retain from AWS console at aws.amazon.com/agreement).

Bedrock is invoked from DAN’s AWS environment in the United Kingdom, using an EU cross-region inference profile. Requests may be processed in eu-west-2, eu-west-3 or other EU regions.

Anthropic is the model provider, accessed through AWS Bedrock. Anthropic does not receive customer data under a separate contract with DAN.

2.2 Sub-Processor Fallback: AssemblyAI, Inc.

Sub-Processor AssemblyAI, Inc.
Role Sub-Processor Fallback
Status Approved for future use. Not in use. Not enabled.
Location Dublin, Ireland, once EU residency is configured and confirmed in writing.
Service Provided Transcription. Sub-Processor Fallback.
Data Processed Patient audio and transcripts. Special category health data. Transmitted only if enabled under DPA clause 5.4.
Safeguards Business Associate Agreement (BAA) in place.

Zero Data Retention configured and enforced.

EU data residency (Dublin) enabled and evidenced.

Audio not used for model training.

SOC 2 Type 2;

ISO 27001:2022;

PCI DSS v4.0 certified.

Agreement in Place Signed BAA on file.,

AssemblyAI Data Processing Addendum on file.

EU data residency configuration, dated screenshot on file.

Model training opt-out - dated screenshot on file.

SOC 2 / ISO 27001 certificates on file.

2.3 Sub-Processor Fallback: OpenAI, L.L.C.

Sub-Processor OpenAI, L.L.C.
Role Sub-Processor Fallback
Status Not in use. Not enabled for any Controller.
Location US (EU data residency selected for DAN account)
Service Provided Transcription. Sub-Processor Fallback.
Data Processed Patient audio and transcripts. Special category health data. Transmitted only if enabled under DPA clause 5.4.
Safeguards Business Associate Agreement (BAA) in place.

Zero Data Retention (ZDR) configured on all eligible endpoints used by DAN.

Audio not used for model training.

SOC 2 Type 2;

ISO 27001/17/18/27701 certified.

Agreement in Place Signed BAA on file.

OpenAI Data Processing Addendum on file.

ZDR configuration — dated screenshot retained.

SOC 2 certificate on file.

2.4 Sub-Processor Fallback: Controller Confirmation

Sub-Processor Fallbacks are made available only as a last resort, where DAN cannot provide transcription through its own infrastructure. It is used for a Controller only after that Controller has confirmed in writing, by ticking the confirmation in the DAN account settings, that it wishes it enabled. The confirmation records the name of the person confirming, the date and time, the account and the version of the DPA. No Sub-Processor Fallback is enabled for any Controller at the date of this register.

Where no fallback is enabled, all transcription is performed within DAN’s own AWS infrastructure and no patient audio is sent to any third party.

Practices are responsible for informing patients through their patient privacy notice. UM0080 provides examples of suitable wording.

3. Sub-Processor Change Process

When DAN proposes to add, replace, or remove a sub-processor, the following process applies in accordance with clause 5.2–5.3 of the Practice DPA:

Step Action Who Timing
1 Update this register with proposed new/changed sub-processor details. DAN DPO Before notice is sent
2 Send Sub-Processor Change Notice to all affected practices, providing the name, location, and nature of processing of the proposed sub-processor. DAN Legal / Operations At least 30 days before change takes effect
3 Allow a 14-day objection window. If a practice objects in writing with reasonable grounds, DAN must work in good faith to resolve the objection. DAN DPO / Legal Days 1–14 after notice
4 If no objection is received within 14 days, the change is deemed accepted. Update the Practice DPA reference and this register. DAN DPO Day 15 after notice
5 Obtain and file all required agreements for the new sub-processor (BAA, DPA, ZDR confirmation, certifications) in the physical file (Section 4). DAN Legal / Engineering Before sub-processor goes live
6 Update DPIA 72, Privacy Policy, and EULA references to reflect the change. DAN Legal / DPO At time of change
7 Publish updated register at https://dentalaudionotes.com/app/privacy. DAN DPO At time of change

4. Physical File Maintenance

DAN maintains a physical evidence file for each sub-processor — a dedicated folder in the DAN document management system, accessible to the Data Protection Officer and Legal team only. This file contains the signed agreements and evidence of compliance measures for each provider.

5. Review Schedule and Sign-Off

This register will be reviewed and updated: