Before a real-data pilot: contact support@cuebooks.co.uk to agree the processing scope, provider arrangements and retention instructions. This page explains the requirements; it is not a signed Article 28 data-processing agreement or a claim that provider due diligence is complete.
1. Who decides what happens
Your business normally acts as controller for customer, supplier and staff information in its books. It decides the purpose, lawful basis and which information is appropriate to upload. Twin Origin Ltd acts as processor when operating Cuebooks on those instructions.
For our own account administration, support and security purposes, we may act as controller as described in the privacy notice. The roles depend on the activity, not just the label on the software.
2. What needs to be agreed
A real-data processing agreement must cover the purpose and duration of processing; types of information and people involved; documented instructions; confidentiality and security; permitted subprocessors; assistance with rights requests, breaches and impact assessments; return/deletion and lawful retention; and the information and audit rights needed to demonstrate compliance. These arrangements need to reflect the actual service and provider contracts.
3. Providers and transfers
Our provider list explains the technical services available to the product. Before agreeing real-data use, we need to confirm the relevant provider agreements, processing locations, international-transfer safeguards and which optional features will be enabled.
A UK domain, a UK company address or a provider’s general compliance statement is not evidence that all processing stays in the UK.
4. Export, correction and retention
Accounting history is designed to preserve evidence. Posted entries are corrected through linked changes rather than silently rewritten. Privacy requests still need to be assessed; accounting immutability does not cancel data-protection rights.
The current accounting export and archive tools are not complete erasure or subject-access workflows. Agree the handling of originals, authentication records, provider copies and backups as part of the pilot’s arrangements.
5. Start safely
Use fictional or appropriately anonymised examples while evaluating the product. If you want to use real business records, email support@cuebooks.co.uk with the kind of business and features you want to test—without attaching those records. We can then identify the necessary arrangements before information is shared.