What about vendor and sub-processor compliance?
Under the GDPR, you remain responsible for ensuring that your processors and their sub-processors comply with data protection requirements throughout the entire relationship.
Best practices for vendor and sub-processor compliance include:
- Review and negotiate Data Processing Agreements (DPAs): Clearly define roles, responsibilities, data handling standards, and breach notification timelines.
- Perform vendor due diligence before engagement: Review security certifications, GDPR readiness, and any regulatory or breach history.
- Maintain an up-to-date vendor register: Record all services, categories of data shared, and associated risk levels.
- Classify vendors by risk: Apply stricter controls and continuous monitoring for high-risk or sensitive data processors.
- Ensure sub-processor transparency: Require vendors to disclose all sub-processors and ensure they are bound by GDPR-compliant contracts.
What are the best practices for vendor monitoring over time?
Initial due diligence is only the first step. Maintaining ongoing visibility into your vendors’ data protection practices is essential for continued compliance.
Recommended best practices include:
- Reassess vendor compliance periodically, ideally every year or during contract renewal.
- Request updated certifications or audit results, such as ISO 27001, SOC 2, or independent GDPR compliance reports.
- Conduct spot checks or follow-up risk assessments, especially for vendors handling sensitive or high-risk data.
- Track security or privacy incidents involving third parties and review how they are managed or mitigated.
- Use automated vendor monitoring tools when working with a large number of external processors.
- Implement a formal offboarding process to ensure all personal data is securely returned or deleted at the end of a contract.
Proper vendor and sub-processor management not only supports GDPR compliance but also strengthens your organisation’s overall data security posture and resilience.