Question: Are subcontractors and sub-processors subject to equivalent security and privacy controls?

Why This Matters

Your risk extends to your suppliers’ suppliers. Assuring that sub-processors meet equivalent standards closes the accountability loop.

Maturity

0 — Unaware
No visibility into sub-processors.

1 — Ad Hoc
Sub-processors declared only after contract signing.

2 — Defined
Vendors required to list sub-processors and seek approval.

3 — Managed
Sub-processors assessed using same criteria as primary vendors.

4 — Integrated
Sub-processor register maintained and periodically audited.

5 — Optimized
Real-time visibility of sub-processing chain and continuous compliance attestations.

How to Level Up

| From → To | Actions | |—|—| | 0 → 1 |Ask all vendors to disclose sub-processors.| | 1 → 2 |Add approval requirement in contract.| | 2 → 3 |Assess declared sub-processors using TPRM criteria.| | 3 → 4 |Maintain register and review annually.| | 4 → 5 |Enable real-time visibility through attestation portal. |

Enablers

People: Vendor Manager, Legal, Privacy Officer
Process: Identify → Assess → Approve → Monitor
Technology: TPRM portal, register database

Evidence

Sub-processor register
Assessment records
Approval logs

KPIs

Number of declared sub-processors
Percentage approved and assessed
Frequency of review

Low-Cost / Open-Source Options (MSME)

Common Pitfalls

No tracking of fourth-party dependencies
Vendors change sub-processors without notice
Register not kept current

Compliance Mapping