Data Processing Agreement

Overview

This page summarizes the standard FMS Data Processing Agreement. The executable version — including jurisdiction-specific annexes (GDPR Art. 28 terms, SCCs where transfers apply, and US state-law addenda) — is provided for signature during scoping. Every engagement that touches personal data gets a signed DPA; it is standard, not an upsell.

Roles

For personal data contained in datasets you upload, you are the controller (or a processor acting for your own controller) and FMS is your processor. FMS processes such data only on your documented instructions: the SOW and the run specs you approve.

Core commitments

• Purpose limitation — your data is used exclusively to execute your engagement. Never to train models for other clients, never for FMS-owned models.
• Confidentiality — access limited to engineers assigned to your engagement, all bound by confidentiality obligations.
• Security — encryption in transit and at rest, per-organization isolation, role-based access, audit logging of every pipeline event.
• Subprocessors — a published list, advance notice of changes, and the right to object.
• Breach notice — notification without undue delay and within 72 hours of confirming a personal-data breach affecting your data.
• Deletion & return — at engagement end, datasets and intermediate artifacts are returned and/or deleted per the schedule you choose; certification of deletion on request.
• Assistance — support for data-subject requests, DPIAs and regulator inquiries relating to processing under the engagement.

PII in the pipeline

The Ingest stage automatically flags likely PII in uploaded datasets. Flagged fields are quarantined until you confirm how they should be handled — excluded, pseudonymized, or processed under the DPA — and that decision is recorded in the run's audit trail.

Get the signable version

Request the executable DPA at legal@futuremodelsystems.com or during scoping. Redlines are welcome on Partner engagements.