Security pack

Data protection position

Why the supplier is neither controller nor processor for your documents, what that means for a DPA, and the honest limits of the redaction and erasure functions.

Describes Oxofolio 0.2.1. Generated from the application's source; the release build fails if it is out of date with the code.

Roles

The customer is the data controller — or, where the customer processes on behalf of its own client, the processor. The supplier is neither. The application transmits nothing and the supplier operates no infrastructure that receives customer data, so the supplier does not process personal data on the customer's behalf and is not a processor under Article 4(8) GDPR or a Data Processor under section 2(k) of the Digital Personal Data Protection Act 2023.

A data processing agreement is therefore not required for the software itself. Suppliers who claim otherwise are usually describing a hosted service.

Cross-border transfer

None. Processing takes place on the machine the software is installed on. There is no transfer to a third country under Chapter V GDPR, and no transfer outside India under section 16 of the DPDP Act.

What the application does for the customer's own obligations

It does not make the customer compliant, and it is not sold as doing so. Compliance is a property of the customer's practices. What the application provides is evidence and tooling for specific obligations:

ObligationWhat the application provides
Article 30 GDPR — records of processingA draft record built from what was actually processed, with the fields only the firm can answer left visibly outstanding
Article 5(1)(e) GDPR, DPDP s.8(7) — storage limitationA retention clock anchored to a statutory basis the firm cites, and certified erasure with a hash of everything destroyed
Article 32 GDPR, DPDP s.8(5) — security of processingLocal-only processing, OS-keystore password storage, SHA-256 of every input and output
Article 17 GDPR — erasureTrue redaction that removes text rather than covering it, verified by re-reading the output
DPDP s.8(3) — accuracy and completenessDuplicate detection and a guard against one client's documents sitting in another's folder

Limits of the redaction and erasure functions

Stated here because a customer relying on them needs to know:

  • Redaction removes the text from the document and the output is re-read to confirm the identifier is gone. Documents with no text layer are refused rather than covered with a rectangle.
  • Erasure overwrites and unlinks, which is NIST SP 800-88 *Clear*. It is not *Purge* or *Destroy*. On a solid-state drive, wear levelling can leave the original block intact until the controller reuses it, and a copy-on-write filesystem can retain the earlier version in a snapshot. Full-disk encryption is what makes such residue worthless, and the erasure certificate records whether it was enabled.
The rest of the pack

The other documents a review asks for.

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Security overview

The architecture, process by process: what the renderer can reach, what the sidecar can reach, and where the network surface would be if there were one. Start here.

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Vendor security questionnaire

The questions a supplier review asks, answered — including the ones where the answer is unfavourable. Signing, penetration testing, certifications and logging are all in here.

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Deployment notes

Installing without administrative rights, what the application writes and where, and what to allow through an endpoint agent.