7.2.6 Contracts with PII processors
The organization must have a written contract with every processor it uses and must ensure those contracts address implementation of the appropriate processor controls, requiring the processor to implement them in light
4
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
- Evidence the risk assessment and processing scope informed which controls were required · Vendor register / contract repository
governing documentDocuments that govern the control
- Written contract with every processor, with a register reconciling contracts to processors actually used · Vendor register / contract repository
- Contract terms addressing the processor control set · Vendor register / contract repository
- Justification for any processor control not required, recorded in the Statement of Applicability · 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
- Processors engaged under standard purchasing terms with no privacy schedule
- Contract requiring appropriate measures generically, so no specific control is enforceable
- Controls omitted by silence rather than by justified exclusion
- Processor register incomplete, most often missing tools adopted by individual teams
- Contract signed at onboarding and never revisited when the scope of processing grew
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 sheet7.2.5 Privacy impact assessment · 7.2.7 Joint PII controller