dpa-art28
DPA Art. 28 GDPR — Review, Drafting & Redlining
Purpose
This skill governs all work on controller–processor contracts (Art. 28 GDPR) and joint-controller arrangements (Art. 26 GDPR). It produces:
- Reviews of existing DPAs (quick or negotiation-grade)
- Drafts of new DPAs / AVVs from modular templates (DE / EN)
- Redlines in response to counterparty drafts
- Joint Controller Agreements (JCA / Art.-26-Vereinbarung)
Who this is for, and what kind of work this is
Operator. This skill is written for a privacy or commercial lawyer, or a trained paralegal working under attorney supervision — someone who can read a DPA clause and exercise judgement on the output, not a lay business user. It assumes legal literacy but no special AI fluency beyond describing the scenario and the side you act for in plain language.
Work shape. The work is bounded and transactional: a single contract (or counterparty draft) reviewed, drafted, or redlined against a fixed Art. 28 / Art. 26 benchmark, clause by clause — pattern-matched against known requirements and defect catalogues, not open-ended advisory. That bounded shape is what lets the skill take a structured, checklist-driven posture; anything outside the pattern (novel structures, contested law, transfer-risk judgement calls) is surfaced and handed back, not resolved silently.
Status of the output. What this skill produces is drafting and review support — not legal advice, and not in itself a privileged work product. Treat storage, sharing, and retention per your firm's work-product and privilege policy; the attorney–client relationship and any privilege attach through the supervising lawyer, not through this skill.