Plain-prose summary of the controller-to-processor relationship in the Sigil DPA. The binding obligations live in the DPA itself; this section is what a DPO reads before opening the agreement.
Sigil processes tenant data as a processor on behalf of the customer, who remains the controller under the GDPR. The Art. 28-style controller-to-processor relationship is recorded in the Data Processing Agreement (DPA) — this page is the plain-prose summary a DPO reads before signing it.
Sigil processes the theme, template, and CSS source the customer pulls into the platform, the scan output Sigil produces against that source (axe-core diagnostics, criterion tags, evidence hashes), the pull requests Sigil files against the customer repository, and the customer account metadata required to keep the service operating (org name, billing email, seat count, audit log).
Sigil does not process special-category data under Art. 9 — no health, biometric, racial, ethnic, religious, political, trade-union, or sexual-orientation data flows through Sigil in the course of normal operation. If your tenant introduces that data into the source tree you bring into Sigil, it falls outside Sigil’s processing envelope and remains your own controller-side obligation.
Sigil processes the data only on documented instructions from the controller. The scanner runs the criteria the controller has selected (the SIGIL_RULES allowlist in the customer configuration); the PRs file against the controller repository; no Sigil feature reads, indexes, or profiles production traffic of the customer application.
Sigil ensures that persons authorised to process personal data are committed to confidentiality and process it only as instructed. Sigil staff with production access are listed in the staff-access register returned with the procurement pack; quarterly access reviews are recorded against the same register.
Sigil implements the technical and organisational measures summarised in the encryption section of this page and detailed in the SoA. Those measures are reviewed quarterly and material changes are reflected in this page within the same window.
Sigil engages the sub-processors listed on this page only under a written contract that imposes the same data-protection obligations as the DPA and that gives the controller the right to audit the sub-processor. Customers are notified ≥ 30 days before any new sub-processor is added, and may object on reasonable grounds related to data protection.