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.