LebSource

Commercial

Sub-processor

A supplier's own supplier that also touches your data.

Definition

Any third party a processor engages to help deliver the service, where that party also handles personal data: hosting providers, ticketing tools, analytics, subcontracted staff. Under GDPR the client must be informed of them and normally has a right to object.

Why it matters

Your data footprint is the whole chain, not just the company you signed with. Ask for the sub-processor list and the notification process for changes. The recurring failure is a provider adding a new tool mid-engagement, moving customer data into a system you never assessed and could not have named.

Next step

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