Data Processing & Data Use Policy

1. Purpose

This document describes how ChronoSeal processes, stores, and protects customer data when providing its time-recording and verification platform ("Service"). It supplements the Terms of Service and Privacy Policy and is intended to provide operational transparency to customers, partners, and auditors.

2. Roles and Scope

For all employee-related data processed through the Service:

• The Customer (employer) is the Data Controller
• ChronoSeal acts as the Data Processor

ChronoSeal processes data only on behalf of the Customer, only for the purpose of delivering the Service, and in accordance with applicable data protection laws including GDPR.

3. Categories of Data Processed

Core Operational Data

• Staff identifiers (staff_id, user_id)
• Staff name
• Location identifiers
• Time event data (clock-in, clock-out, breaks)
• Session dates and timestamps

Authentication Data

• Login email (for admin and employee access)
• PIN codes (stored as secure hashes only)
• Authentication and access logs

System Data

• Device identifiers (kiosk or client device)
• Event metadata required for system operation
• Security and audit logs

Verification Data

• Cryptographic event hashes
• Chain references (previous_hash)
• Daily seal records (root_hash)
• Timestamp proofs (TSA / eIDAS where applicable)

4. Purpose of Processing

ChronoSeal processes data strictly to record and manage employee working time, maintain a tamper-evident append-only event ledger, generate verifiable records, enable audit and compliance workflows, provide employee self-access, and ensure system security.

ChronoSeal does not sell data, use data for advertising, or profile employees for independent purposes.

5. Data Storage and Architecture

ChronoSeal uses a structured, append-only data model. Events are written as immutable records. Each event is cryptographically linked to the previous event. Daily seals provide verification checkpoints. There is no deletion or mutation of recorded events, full audit history is preserved at all times, and corrections are additive, not destructive. This model is fundamental to the integrity of the system.

6. Data Location

All primary data is processed and stored within the European Union (Western Europe data centres). ChronoSeal is designed to keep customer data within the EEA wherever possible.

7. Subprocessors

ChronoSeal may engage trusted subprocessors including cloud infrastructure providers, authentication services, payment processors, and timestamping authorities. All subprocessors are selected based on security and compliance standards, process data only as necessary, and are bound by contractual data protection obligations. A list of subprocessors may be provided upon request.

8. Data Security Measures

ChronoSeal implements technical and organisational safeguards, including:

• Encryption in transit (TLS)
• Secure hashing of sensitive data (e.g. PINs)
• Role-based access control
• Principle of least privilege (access by necessity only)
• Rate limiting and lockout mechanisms
• Continuous logging of security-relevant events

9. Data Integrity and Verification

Every event is cryptographically hashed. Each record is linked to the previous event. Daily seals provide verifiable checkpoints. Records can be verified via ChronoSeal interfaces or independently using exported data — ensuring records are tamper-evident and integrity can be validated without reliance on ChronoSeal systems.

10. Employee Access and Transparency

Employees can access their own records via a secure portal, view full event history and sealed records, export their data and verification bundles, and independently verify their records. This supports both data subject rights under GDPR and trust between employer and employee.

11. Data Retention

ChronoSeal retains data for the duration of the Customer's subscription and in accordance with Customer instructions. Customers are responsible for defining retention policies, ensuring compliance with labour and tax regulations, and retaining exported records where required.

12. Data Portability

ChronoSeal provides export capabilities including raw event data, verified day records, cryptographic chain data, and verification bundles for independent validation. Exported data can be stored independently and verified without access to ChronoSeal systems.

13. Data Deletion and Corrections

Due to the append-only design, recorded events are not deleted or modified. Corrections are implemented as new events referencing prior records. This approach ensures full auditability, preservation of historical truth, and resistance to tampering.

14. International Transfers

ChronoSeal is designed to minimise transfers outside the EEA. Where international processing occurs (e.g. via subprocessors), safeguards include Standard Contractual Clauses (SCCs) and use of providers with recognised adequacy frameworks.

15. Incident Response

In the event of a data security incident, ChronoSeal will investigate and contain the issue, notify affected Customers where required, and provide relevant information to support compliance obligations. Customers remain responsible for any required regulatory notifications as Data Controllers.

16. Changes to this Policy

ChronoSeal may update this document from time to time. Material changes will be communicated via email or in-app notification.