Legal
Privacy notice: Custom Field Cleanup & Where-Used for Jira
This notice explains what personal data our Jira Cloud app Custom Field Cleanup & Where-Used for Jira (the “app”) handles, where it is kept, and your rights. Our terms for the app are at neirfeno.com/custom-field-cleanup/terms.html.
Who we are
The app is made by Neirfeno Limited, a company registered in Scotland (company number SC514019), registered office 7 Thorter Way, Dundee DD1 3DF, United Kingdom. Contact us about privacy at contact@neirfeno.com. We pay the data protection fee to the UK Information Commission (still known as the ICO), registration number ZB673603.
Our role
- Your organisation (the Jira site that installs the app) decides to use the app and is the controller of the Jira data the app reads and stores.
- We are your organisation’s processor for that data. Our app processes it only to provide the app’s features for your organisation, under our data processing terms (Schedule 1 of our terms).
- Atlassian runs the app and stores its data on its Forge platform. It is our sub-processor, under Atlassian’s Forge Data Processing Addendum.
- We are a controller only for the emails people send us at contact@neirfeno.com (see “Support emails” below). We are not a controller of any data the app processes.
- Atlassian is the controller of the data it collects when your organisation buys, trials or renews the app on the Atlassian Marketplace. We don’t use that data for this app.
- We, not Atlassian, are responsible for how our app processes personal data.
If you are a Jira user and want to use your data protection rights for data in Jira or in the app, contact your organisation’s Jira administrator first. We will help them.
What the app stores
The app stores everything in Atlassian’s Forge SQL storage for your Jira site. It has no servers of its own.
Account IDs. The app keeps Atlassian account IDs for filter and dashboard owners, and for the admin named in each audit log entry (who moved a field to the trash or restored it). It does not store display names or email addresses. When a page in the app shows a person’s name, the app looks it up from Jira at that moment, shows it to the viewer, and does not save it. Accounts Jira can’t find are shown as “Former user”.
Jira configuration. To show where things are used, the app stores a copy of your Jira configuration: custom fields and their contexts, screens, schemes, workflows, statuses, projects, saved filters (including their JQL), boards, dashboards and gadgets, and the links between them. Your users wrote some of this, such as the names of filters, boards, dashboards, gadgets and fields, and filter JQL, so it can contain personal data. For example, a filter might be called “Jane’s open bugs”, or its JQL might name an assignee by account ID.
What the app doesn’t read or store: issue content (summaries, descriptions, comments, attachments), passwords, API tokens or payment details.
No AI. The app does not use artificial intelligence or machine learning. It makes no automated decisions about people.
Atlassian’s personal-data reporting
Atlassian requires apps that store account IDs to report them regularly. Once a week, the app sends the account IDs it stores to Atlassian’s own personal-data reporting service (api.atlassian.com). When Atlassian says an account has been closed, the app replaces that account ID with the fixed text “closed-account”. The audit entry itself (action, fields and time) is kept. This is the app’s only connection outside your Jira site, and it goes to Atlassian. Account IDs never leave Atlassian.
Logs
The app writes technical logs to Atlassian’s Forge logs, which Atlassian holds and deletes after 30 days. The app itself never writes account IDs, display names or email addresses to its logs. The logs can, however, include:
- the names of filters, boards, dashboards, gadgets and custom fields; and
- Jira’s error messages for saved filters whose JQL is broken. These can quote parts of the JQL, including field names and any value typed into the query, such as a person’s name, email address or account ID.
Atlassian lets us, as the app’s developer, see these logs in Atlassian’s developer console, so that we can fix problems. We use them only to support the app for your organisation. Your Jira admins can turn off our access at any time in Atlassian Administration (Apps > Connected apps > Custom Field Cleanup & Where-Used for Jira > Logs access).
Who can see the data
- People in your organisation who can open the app. It is available to Jira administrators only.
- Atlassian, which hosts the app and its storage, as our sub-processor (see Atlassian’s sub-processor list at atlassian.com/legal/sub-processors).
- Us, only through the logs described above. We don’t access the app’s stored data for your site, Atlassian’s developer tools don’t show it to us, and the app sends nothing to us.
We don’t sell or share the data with anyone else, and we don’t use it for advertising.
Where the data is kept (data residency)
Everything the app stores is in Forge SQL, Atlassian-hosted storage that supports data residency. It is held in the same data-residency location as your Jira site and moves with it if your admin moves the site. If your site isn’t pinned to a location (“Global”), Atlassian chooses where it is held. Nothing the app stores is kept outside Atlassian.
- In scope for data residency: all app data in Forge SQL (the account IDs, Jira configuration copy, findings, settings and audit log described above).
- Out of scope: the Forge logs described above, and processing at the moment a page is viewed. Atlassian may sometimes run the app’s code from a region other than your site’s.
International transfers. We are in the UK, which the European Commission recognises as giving adequate protection to data from the EEA. When we view logs, that happens from the UK. Atlassian’s hosting for us is covered by the EU standard contractual clauses and UK provisions in its Forge Data Processing Addendum.
How long it is kept
- While the app is installed: the app keeps its data for as long as it is installed. Each scan removes items that no longer exist in Jira. The audit log is kept until the app is uninstalled.
- Logs: 30 days, by Atlassian.
- When you uninstall the app: the app can no longer read its data. Atlassian keeps the data in a soft-deleted state for 28 days and then deletes it. If you reinstall the app and want the earlier data back, ask us within 21 days of uninstalling. With your consent, we will ask Atlassian to re-link it to your new installation. After that, it can’t be recovered. We never hold a copy of the app’s data.
- Fields in Jira’s trash: these are part of Jira, not the app. Jira keeps them restorable for 60 days whether or not the app is installed.
Support emails (where we are controller)
If you email us at contact@neirfeno.com, we receive your name, email address and whatever you write. We use this to reply and give support, and to keep business records. The legal basis is our legitimate interest in answering and supporting the people who contact us (UK GDPR Article 6(1)(f)). We don’t use it for marketing unless you agree. Our email is provided by Google Workspace (Gmail). We keep support emails for up to 5 years after our last exchange, so that we can deal with any questions or claims.
Your rights
Under UK data protection law (and the EU GDPR where it applies), you have the right to ask for access to your personal data, and to ask for it to be corrected, erased or restricted. You can object to processing based on legitimate interests, and in some cases you can ask for a portable copy.
- For data in Jira or in the app, contact your organisation’s Jira administrator. They control it, and we will help them.
- For contact and support data, contact us at contact@neirfeno.com.
Complaints
If you are unhappy with how we have handled your personal data, please complain to us first at contact@neirfeno.com. You also have the right to complain to the Information Commission (ico.org.uk), or to the data protection authority where you live.
Changes
If we change this notice, we will publish the new version here with a new date, and tell customers through the app’s Marketplace listing if the change is significant.