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GDPR Contract Remediation for Cognizant Technology Solutions

In September 2017, Cognizant approached Integreon to assist in ensuring that their customer, vendor and sub-processor (internal and third-party) contracts are GDPR compliant.

  • 2,000
    client and counterparty contracts in English & multiple non-English languages
  • 10
    months to complete

The Approach

The project requires Integreon to review, amend and negotiate more than 2,000 contracts, from multiple jurisdictions, over a period of ten months. It also entails reviewing contracts on third-party paper to incorporate the GDPR requirements, including drafting any requisite amendments and exhibits.

Integreon set up a dedicated team of ten GDPR contract specialists and two senior GDPR negotiators in its Mumbai delivery center. In close collaboration and consultation with Cognizant’s in-house privacy team, Integreon developed a comprehensive GDPR remediation playbook and workflow document. The approach adopted by the team ensures that only the legal obligations imposed by the GDPR are applicable to Cognizant, and that no transfer of undue obligations is made under the contract. In order to achieve this, the team is required to fully comprehend both the roles of Cognizant and the counterparties under each in-scope contract and ascertain whether each would be treated as a processor or as a controller and make changes accordingly. These changes can include the incorporation of the applicable EU model clauses to the contract that lay out the requirements of the processor or controller.

“We chose Integreon because of their demonstrated expertise in regulatory driven contract review and repapering. Integreon’s substantive understanding of commercial contracts and its ability to adapt to GDPR requirements, along with their highly efficient, process driven approach to the engagement has freed our global in-house legal team to concentrate on other, higher-value tasks.” – Simon White, General Counsel UK, Middle East & Africa; Global Privacy Director - Cognizant

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