EvidenceSheet

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.

3
artefacts
0
held by a system
2
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. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

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

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

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.

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P6.3 Record of unauthorised disclosures and breaches · P6.5 Vendor commitments to report unauthorised disclosures