FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / issues-memorandum-dpa-v2-0.docx
issues-memorandum-dpa-v2-0.docx · 1007-00007

Parties

Harkness LLP
Vantage Mobility Systems Corp
Crane LLP
Regarding Pinehurst Cybersecurity Advisors LLC
Pinehurst Cybersecurity Advisors LLC

Dates

November 4, 2022
October 21, 2022
October 7, 2022
January 15, 2022
July 1, 2022
July 1, 2023
August 5, 2022
March 1, 2021
February 28, 2024

Amounts

$2,500
$15,000,000
$6.5
$7,500
$840
$15
$78
$19.5
$2.8
$13,000,000

Obligations

Specifically, after Meridian has completed its processing of raw telemetry data and delivered the resulting analytics outputs (predictive maintenance insights, driver behavior scores, and fleet optimization analytics) to VMS or to authorized third-party recipients, Meridian is required to irreversibly delete or anonymize all raw data within ninety calendar days of initial receipt
100(c), a business's collection, use, retention, and sharing of a consumer's personal information must be "reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed
The general authorization model proposed by WBC effectively shifts the default from "consent required" (processor must obtain affirmative approval) to "consent presumed unless objection raised" (controller must monitor, evaluate, and affirmatively object)
Regardless of the approval model ultimately adopted, the DPA must require Meridian to impose substantially identical data protection obligations on all sub-processors through written sub-processing agreements
The key question is not whether sub-processors must comply with equivalent obligations, but rather who controls the decision of whether to engage a particular sub-processor in the first instance
SOC 2, ISO 27001), a description of the processing activities to be performed, the data categories involved, and a summary of the sub-processor's security posture; (ii) VMS's objection may be based on "reasonable data protection grounds," a standard that is broader than WBC's proposed "reasonable grounds" formulation and that expressly encompasses concerns relating to the sub-processor's security posture, jurisdiction, regulatory compliance history, and data governance practices — not limited to material security deficiencies; (iii) If VMS objects and the parties cannot resolve the dispute within fifteen business days through good-faith escalation to senior representatives, VMS retains the right to terminate the DPA for convenience without penalty or early termination fee; and (iv) Meridian must, in all cases, execute a written sub-processing agreement with each sub-processor imposing data protection obligations substantively equivalent to those imposed on Meridian under the DPA, and must provide copies of such sub-processing agreements to VMS upon request