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UK GDPR evidence

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circle.soLast verified 21 Sep 2026
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UK GDPR, with the Data Protection Act 2018

CircleCo against UK GDPR’s vendor requirements

4 provisions of UK GDPR reach the vendors you rely on. For each, the public evidence from CircleCo that may support it, with its date and source.

2 evidence found1 partial evidence1 no public evidence
Article 28(1)

Use processors that provide sufficient guarantees

A controller shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures.

Evidence found

  • Independent security assurance

    Evidence found

    A current SOC 2 report or ISO/IEC 27001 certificate is the usual evidence that a supplier operates appropriate security measures.

    • SOC 2Vendor states SOC 2 Type II on its trust centreas of 21 Sep 2026
    • SOC 2 report"SOC 2 Type II Attestation" on the trust centreas of 21 Sep 2026
    • SOC 3 report"SOC 3 (Full report)" on the trust centreas of 21 Sep 2026

  • Security testing and documentation

    Evidence found

    A penetration test report, a completed standard questionnaire (SIG, CAIQ, HECVAT) or security documentation shows how the supplier tests and runs its controls.

    • Penetration testing"Does Circle conduct penetration tests?" Circle engages with one of the best penetration testing consulting firms in the industry at least annually. Our current preferred penetration testing partner is Redseer Security. All areas of the Circle product (web +...as of 21 Sep 2026
    • Security policy or overview"Access Control Policy" on the trust centreas of 21 Sep 2026
    • Security policy or overview"Cryptography Policy" on the trust centreas of 21 Sep 2026
    • Security policy or overview"Human Resource Security Policy" on the trust centreas of 21 Sep 2026
    • and 3 more
Article 28(3)

Put processing under a written contract

Processing by a processor must be governed by a contract with the terms Article 28(3) lists, including documented instructions, confidentiality, security and assistance.

No public evidence

  • Data processing agreement

    No public evidence

    The DPA is where processing instructions, confidentiality, security, sub-processing and audit rights are written down.

Article 28(2) and (4)

Know and control sub-processors

Sub-processors need the controller’s authorisation, changes must be notified, and obligations flow down by contract.

Evidence found

  • Published subprocessor list

    Evidence found

    A current list of subprocessors, with purpose and location, is how a customer knows who else touches its data.

Articles 44 to 46

Transfer data outside the UK lawfully

Restricted transfers need UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or appropriate safeguards such as the International Data Transfer Agreement or the UK Addendum to the EU SCCs.

Partial evidence

  • Transfer mechanism

    Expired

    Transfers outside the EU or UK need a basis such as an adequacy decision (including the EU-US Data Privacy Framework) or standard contractual clauses.

  • Where data is hosted and processed

    Evidence found

    The regions or countries where the service runs and data is stored, from the vendor or its subprocessor list.

    • Where data is hosted or processed"Where can I find Circle's Data Processing Addendum (DPA)?" Circle's DPA can be found at https://circle.so/dpa. Our DPA binds Circle to appropriate security, prompt breach notification, cooperation with you and regulators, assistance with data-subject requests, and flow-down o...as of 21 Sep 2026
    • Where data is hosted or processed"Where does Circle host customer data?" Circle hosts all data in AWS US-East-1 (Northeast US). Please note that Circle doesn't currently offer the option to host data in any other locations. This means that by using Circle's services, personal data will be...as of 21 Sep 2026
    • Hosting regionsHosting regions stated: EU, UK, USas of 21 Sep 2026
    • Subprocessor locations20 of 20 subprocessors list a locationas of 21 Sep 2026

Questions buyers ask

Is CircleCo UK GDPR compliant?

CertReports does not decide that. It shows the public evidence that may support each UK GDPR requirement that reaches vendors: evidence was found or is available on request for use processors that provide sufficient guarantees (Article 28(1)), know and control sub-processors (Article 28(2) and (4)), and nothing public was found for put processing under a written contract.

What should I ask CircleCo for?

Request data processing agreement, and confirm each is current.

Reading for UK GDPR reviews

All articles

This maps third-party obligations to the vendor evidence that may support them. It is not legal advice and never a statement that a vendor or its customers comply; confirm scope and sufficiency with your counsel or auditor. “No public evidence” means nothing public was found at the last check. Citations link to the official text.

Requirements reviewed 21 Sep 2026. The vendor lists the evidence on its trust centre behind a request or NDA; ask for it.