8.5.8 Change of subcontractor to process PII
Where it holds a general written authorization, the organization must inform the customer of any intended change involving the addition or replacement of a subcontractor that processes personal data, giving the customer
4
artefacts
0
held by a system
2
at each review
hard
to go live
Document 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
- Records of notifications given and objections received, with outcomes · Document repository
- Evidence that new subcontractors did not begin processing before authorization · Document repository
governing documentDocuments that govern the control
- Change notification procedure with the notice period and the objection route · Policy repository / GRC workspace
- Contract terms establishing the general authorization and its conditions · 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
- Notification given at the point of change or after, so the objection right is theoretical
- Objection received and overridden commercially with no record of the resolution
- Replacement subcontractor onboarded and processing during the notice period
- Notification published on a webpage the customer is expected to monitor rather than sent
- No notice period defined, so timely is whatever the organization decides
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