Description

The Data Processing Agreement for AI Vendors is a specialized legal contract that governs how AI vendors
handle personal and sensitive data. Standard DPAs fail to address the unique risks of AI systems: automated
decision-making, model training on processed data, algorithmic transparency requirements, and cross-border
data flows for inference. This template incorporates GDPR Article 28 requirements while extending protections
for AI-specific processing activities, making it essential for any organization sharing customer data with
AI-powered services.
What’s Included
• AI-Enhanced DPA Template – 15-page agreement covering data processing scope, subprocessor
management, AI-specific processing activities, model training restrictions, audit rights, breach notification,
and termination procedures
• Standard Contractual Clauses Addendum – Pre-written SCCs for international data transfers with
AI-specific modifications for transfer impact assessments
• Subprocessor Assessment Checklist – Vendor evaluation tool for approving AI vendor subprocessors
including cloud providers, API wrappers, and training partners
Key Differentiators
This DPA includes provisions for: explainable AI requirements under Article 22 GDPR, automated
decision-making opt-outs, algorithmic impact assessment requirements, model card documentation mandates,
and synthetic data generation rules. The template addresses emergent AI risks like prompt injection attacks,
training data poisoning, and inference-time data extraction. Unlike standard DPAs, this agreement specifically
prohibits repurposing data for foundation model training.
Target Audience
Data protection officers, privacy counsel, procurement managers, and compliance teams who need to contract
with AI vendors while maintaining GDPR, CCPA, and other privacy regulation compliance.