This agreement is between the parish or organisation using Pewbook (the "customer", and the controller) and Lewis Cummins, trading as Pewbook (the processor). It forms part of our terms of service, and the customer accepts it by accepting those terms. It covers what UK GDPR Article 28(3) requires.
1. What, why and for how long
Pewbook processes personal data to run Pewbook for the customer: its public page, service times, staff logins and the modules it uses, such as Mass intentions. This agreement lasts as long as the customer's account.
2. Types of data and people
- People: parishioners and others who send requests, and the customer's staff and volunteers.
- Data: names, email addresses, phone numbers (optional), intention text and what it's for, Mass dates and churches, the choice whether to publish an intention, and staff details (name, email, role, login records and the audit log).
- Special category data: intentions can reveal religious belief.
3. Only on the customer's instructions
Pewbook processes the data only on the customer's documented instructions. Using Pewbook, and choosing its settings, is the instruction. If the law ever requires us to do something else, we'll tell the customer first unless the law forbids it.
4. Confidentiality
Anyone at Pewbook who can access the data is bound to keep it confidential.
5. Security
- The database and server are hosted in the UK and EU.
- All connections are encrypted in transit.
- Every database table uses row-level security that denies all direct access. Data is reached only through Pewbook's server, which checks who is asking.
- Staff log in with a one-time link sent by email. There are no passwords to steal or reuse.
- Changes to the Mass intentions register are recorded in an audit log: who did what, and when.
- Development and live systems use separate databases. Test work never touches live data.
6. Sub-processors
The customer gives general written permission for Pewbook to use these sub-processors:
| Name | What for | Where data is held |
|---|---|---|
| Supabase | The database, where each parish's records are kept. | EU/UK region |
| Fly.io | Runs the Pewbook server. | London, UK |
| Cloudflare | Hosts the website and serves its pages. | Global network |
| Resend | Sends emails: request checks, confirmations and staff login links. | United States, under UK transfer safeguards |
| Stripe | Billing for paid modules. Parish billing details only, never parishioners' data. | UK/EU and United States, under UK transfer safeguards |
| Grafana Cloud (from when we add monitoring) | Server logs and performance measurements. | EU region |
We'll email the customer at least 30 days before adding or replacing a sub-processor. The customer can object. If we can't agree a way forward, the customer can end this agreement and the terms. Each sub-processor is bound by data protection terms at least as strong as these.
7. Helping the customer
Pewbook will help the customer answer requests from people using their data protection rights, such as access or deletion, and pass on any such request sent to us. We'll also help the customer meet its own obligations, such as data protection impact assessments and dealing with the Information Commissioner's Office.
8. Data breaches
If Pewbook becomes aware of a personal data breach affecting the customer's data, we'll tell the customer without undue delay, and within 48 hours, with what we know and what we're doing about it.
9. At the end
When the account ends, the customer chooses whether we return its data (as an export) or delete it, as described in the terms. Records the parish must keep, such as the Mass intentions register, are handed over before anything is deleted.
10. Showing we comply
Pewbook will give the customer the information it needs to show that this agreement is being kept. The customer can ask for an audit, with reasonable notice.
11. Transfers outside the UK and EU
We don't transfer the data outside the UK or EU, except where a sub-processor does so under UK adequacy regulations or the UK International Data Transfer Addendum.
Contact
Lewis Cummins, trading as Pewbook
33 Appleyard Close, Cheltenham, GL51 9FF
[email protected]