DSP-13 Personal Data Sub-processing
Control how personal data is passed to and processed by sub-processors in the service supply chain, in line with applicable law.
4
artefacts
0
held by a system
1
at each review
hard
to go live
Policy repository / GRC workspace
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
- Due diligence records before engagement · Vendor register / contract repository
governing documentDocuments that govern the control
- The sub-processor register with the data each one handles · Policy repository / GRC workspace
- Contractual terms binding sub-processors to the required protections · Document repository
- Evaluation or audit of sub-processor practice · Policy repository / GRC workspace
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
- Sub-processors engaged by delivery teams without the register being updated
- Contracts silent on data protection obligations
- Due diligence at onboarding with no ongoing evaluation
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 sheetDSP-12 Limitation of Purpose in Personal Data Processing · DSP-14 Disclosure of Data Sub-processors