P6.4 Privacy commitments from vendors and third parties
Privacy commitments are obtained from vendors and others outside the organisation that can reach personal information, their compliance is assessed periodically and as needed, and corrective action is taken where necessary. Points of focus: information goes only to third parties with agreements to protect it consistently with the notice, whose controls are evaluated; and misuse by a third party that received information triggers remedial action. As revised in 2022, the organisation also has procedures to evaluate whether third parties meet their privacy commitments.
Source: SOC 2 (2017 Trust Services Criteria), P6.4. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Periodic assessments of vendors' privacy compliance · Vendor register / contract repository
- Records of remediation after vendor misuse · Vendor register / contract repository
governing documentDocuments that govern the control
- Data processing agreements with privacy clauses · Vendor register / contract repository
First move
Common gaps auditors find
- Vendors with personal data access lack a processing agreement
- No periodic check on vendor compliance
- Vendor misuse handled informally
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 sheetP6.3 Record of unauthorised disclosures and breaches · P6.5 Vendor commitments to report unauthorised disclosures