Pre-approved notice for adding, replacing, or removing a sub-processor.
Version: 1.0 Last updated: 1 June 2026
Both the master DPA and UAE Addendum require OMNIA to give schools prior notice of sub-processor changes and a reasonable window to object. This template is pre-approved drafting — no lawyer review required when used verbatim with only the bracketed fields completed.
Notice timing
| Event | Notice required | Objection window |
|---|---|---|
| New sub-processor | At least 30 days before they begin processing | 30 days from notice |
| Replacement sub-processor (same category, same region) | At least 14 days before switch | 14 days from notice |
| Removal of sub-processor | At time of removal (no objection right) | n/a |
| Emergency replacement (security / continuity) | As soon as reasonably practicable | 14 days post-hoc |
If a School objects in good faith and a resolution cannot be reached, the School may terminate the affected subscription without penalty and OMNIA will return or delete the School's data per the DPA.
Email template
Subject: OMNIA — Sub-processor change notice — effective [DATE]
Dear [School DPO name],
Under clause [X] of the OMNIA Data Processing Agreement (and §3.3 of the UAE Jurisdiction Addendum where applicable), we are giving you advance notice of a change to our sub-processor list.
Change type: ☐ Addition ☐ Replacement ☐ Removal
Effective date: [DATE]
Sub-processor details:
| Field | Value |
|---|---|
| Name | [Sub-processor legal name] |
| Service provided | [e.g. transactional email delivery] |
| Category of data processed | [e.g. parent email addresses, no special-category data] |
| Location of processing | [e.g. EEA — Ireland] |
| Transfer mechanism (if outside EEA) | [e.g. EU SCCs Module 3 + UK IDTA] |
| Sub-processor's own certifications | [e.g. ISO 27001, SOC 2 Type II] |
| Replacing (if applicable) | [Previous sub-processor name] |
| Reason for change | [e.g. consolidation, improved security posture, cost] |
Our updated public sub-processor list: https://omnia-inclusion.com/legal/sub-processors (effective [DATE])
Your right to object:
You may object to this change in writing to dpo@omnia-inclusion.com within [30 / 14] days of this notice. If we cannot resolve your objection, you may terminate the affected subscription without penalty under clause [Y] of the DPA, and we will return or delete your data per our retention policy.
If we do not hear from you by [DEADLINE], the change will take effect on the date above.
Yours sincerely,
[Name] Data Protection Lead OMNIA Inclusion Ltd
Internal checklist before sending
- Sub-processor added to / removed from the public list at
/legal/sub-processors - DPA / SCCs / IDTA signed with sub-processor and on file
- DPIA reviewed if the change materially alters the data flow
- Notice sent to all affected school DPOs (not just one)
- Notice logged in the internal sub-processor change register
- Calendar reminder set for the objection deadline