§1798.100(d) Contractual Requirements for Third Parties, Service Providers, and Contractors
A business that collects PI and sells/shares it with a third party or discloses it to a service provider or contractor must enter into a written contract that specifies purposes, prohibits selling/sharing/retaining/using
5
artefacts
0
held by a system
1
at each review
hard
to go live
Vendor register / contract repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Audit/inspection records · Vendor register / contract repository
governing documentDocuments that govern the control
- Service provider/contractor agreements containing all required CCPA clauses · Vendor register / contract repository
- Third party data sharing agreements · Vendor register / contract repository
- Vendor inventory classifying each recipient (service provider, contractor, third party) · Vendor register / contract repository
- Subcontractor flow-down clauses · Vendor register / contract repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Legacy vendor contracts missing CPRA-required clauses
- No classification of recipient role
- No audit rights exercised
- Combining-data prohibitions absent
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet§1798.100 General Duties of Businesses that Collect Personal Information · §1798.105 Right to Delete Personal Information