A contract workflow for Data Processing Agreements under Article 28 of the GDPR, the EU privacy rule for controller–processor relationships, and arrangements between joint controllers under Article 26.

Reviewing, drafting, or redlining DPAs, German AVVs, and joint-controller agreements in English or German.

It gives privacy or commercial lawyers a clause-by-clause basis for reviewing, drafting, or negotiating these arrangements.

dpa-art28 — Skill for Claude Code and Codex by LegalQuants

Install

Getting it into your agent

One page per mod, every tool's command on it. A separate URL per tool would split the same page into five that compete with each other.

Any agent

npx skills add LegalQuants/lq-skills --skill dpa-art28

Clone the repo

git clone --depth 1 https://github.com/LegalQuants/lq-skills

Made for: Claude Code, Codex.

Wrote this? Show the measurements

A badge with what this costs and how it scanned, read live from this page, so it follows the numbers instead of freezing them. Markdown for a README, HTML for a documentation site or a project page.

README.md

[![agentmods](https://agentmods.dev/badge/skills/legalquants/lq-skills/dpa-art28/github.svg)](https://agentmods.dev/skills/legalquants/lq-skills/dpa-art28)

Your own site

<a href="https://agentmods.dev/skills/legalquants/lq-skills/dpa-art28"><img src="https://agentmods.dev/badge/skills/legalquants/lq-skills/dpa-art28/github.svg" alt="Measured on agentmods" height="20"></a>

Or the 80×15 button, for a site that already has a row of RSS and ATOM ones. Only the verdict fits; the numbers stay here.

Your own site · 80×15

<a href="https://agentmods.dev/skills/legalquants/lq-skills/dpa-art28"><img src="https://agentmods.dev/badge/skills/legalquants/lq-skills/dpa-art28.svg" alt="Reviewed on agentmods" width="80" height="20"></a>

Per session 197 Skills are progressive disclosure: only the name and description are preloaded; the body loads when the skill is used.

When invoked 4,202 The whole file, excluding the scripts and references it only reads on demand.

Security scan A 0 findings. A grade says what 26 rules found in the file — not that it is safe.

Origin original No closer match found in the catalogue.

Token cost

What it costs to keep this loaded

Counted locally with the o200k_base tokenizer, which is exact for GPT models; Claude uses its own tokenizer and its counts differ. Treat this as one consistent yardstick across the catalogue rather than a bill. Prices are per million input tokens.

Model	Per session	Once invoked
Fable 5.1	$0.00197	$0.04202
Opus 5	$0.00098	$0.02101
Sonnet 5	$0.00039	$0.00840
Haiku 4.5	$0.00020	$0.00420

Measured 12d ago against content hash 69f7a8a04cad, method: parsed. Prices are Anthropic first-party input rates as of 2026-09-12, from the pricing page.

Security

Grade A, and why

dpa-art28 scanned grade A with 0 findings against 26 rules in 11 categories — prompt injection, anti-refusal, data exfiltration, privilege escalation, supply chain, agent snooping, system-prompt leakage, SSRF and excessive agency — measured 12d ago.

A static scan of the body, not an audit. Every finding is printed with the line that produced it so you can judge whether it matters here. A mod is markdown that instructs an agent; that is exactly why what it instructs is worth reading.

Nothing flagged

None of the 26 patterns this scan looks for appear in this file: no shell pipes, no recursive deletes, no credential paths, no hidden text, no instruction-override or anti-refusal phrasing, no agent-config snooping. That is not a guarantee, it is the absence of the things that are checkable.

skills/dpa-art28/SKILL.md · 194 lines

How it starts

The opening of the file, as written. The whole thing — 194 lines — stays where its author put it; the contents beside it link to each section on GitHub.

Purpose

This skill governs all work on controller–processor contracts (Art. 28 GDPR) and joint-controller arrangements (Art. 26 GDPR). It produces:

Reviews of existing DPAs (quick or negotiation-grade)
Drafts of new DPAs / AVVs from modular templates (DE / EN)
Redlines in response to counterparty drafts
Joint Controller Agreements (JCA / Art.-26-Vereinbarung)

Who this is for, and what kind of work this is

Operator. This skill is written for a privacy or commercial lawyer, or a trained paralegal working under attorney supervision — someone who can read a DPA clause and exercise judgement on the output, not a lay business user. It assumes legal literacy but no special AI fluency beyond describing the scenario and the side you act for in plain language.

Work shape. The work is bounded and transactional: a single contract (or counterparty draft) reviewed, drafted, or redlined against a fixed Art. 28 / Art. 26 benchmark, clause by clause — pattern-matched against known requirements and defect catalogues, not open-ended advisory. That bounded shape is what lets the skill take a structured, checklist-driven posture; anything outside the pattern (novel structures, contested law, transfer-risk judgement calls) is surfaced and handed back, not resolved silently.

Status of the output. What this skill produces is drafting and review support — not legal advice, and not in itself a privileged work product. Treat storage, sharing, and retention per your firm's work-product and privilege policy; the attorney–client relationship and any privilege attach through the supervising lawyer, not through this skill.

Mode router — ALWAYS run first

Before doing anything else, classify the request into ONE of these modes:

Mode	Trigger pattern	Workflow file
`REVIEW_QUICK`	"Is this DPA compliant?", "Art. 28(3)(a)–(h) check", short turnaround, sign/no-sign decision needed	`workflows/review-quick.md`
`REVIEW_NEG`	"Review this for negotiation", "give me redline points", "what should we push back on", deeper diligence	`workflows/review-negotiation.md`
`DRAFT`	"Draft a DPA", "create an AVV", "we need a processor agreement for [X]", greenfield	`workflows/draft.md`
`REDLINE`	Counterparty has sent a DPA, user wants tracked-changes / counter-proposals	`workflows/redline.md`
`JOINT_CONTROLLER`	"Art. 26", "joint controller", "JCA", or roles screen reveals JC not processor relationship	`workflows/joint-controller.md`

Read the full file on GitHub · 194 lines

Files

What ships with it

25 files beside SKILL.md in the same directory: the scripts, references and assets a skill reads on demand. Not counted in the per-session cost; read them before you install if any of them is executable.

Changes

What this file has done since we first saw it

Hashed on every crawl. A supply-chain change to an agent config is a question of when, not whether, so the history is kept rather than the latest state alone.

12d ago First seen · 194 lines · 197 tokens per session scan A 69f7a8a04cad

Subscribe to this mod's changes

dpa-art28 is a skill published in the GitHub repository LegalQuants/lq-skills (54 stars, last pushed 2mo ago), licensed Apache-2.0. It adds 197 tokens to every session and 4,202 once invoked, about $0.0010 per session on Opus 5. A static security scan graded it A with 0 findings. No closer match exists in the catalogue, so it is treated as the original; first seen 2026-08-30.

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