Privacy & Vendor Management Training: Third-Party Risk

HumanShield’s privacy vendor management program equips teams to manage third-party risk end-to-end through practical vendor training and governance. Because vendors, third-party providers, and suppliers form a critical part of every supply chain—and are equal participants in privacy compliance—this training turns contracts and policies into operational controls that work in real engagements.

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Understanding Third-Party Privacy Risks

Third parties expand capability and exposure. This section frames typical third-party privacy risks—from over-broad data access to cross-border transfers, weak deletion practices, and ambiguous breach responsibilities—so you can map risks, threats, and concerns to concrete controls before onboarding a vendor.

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Vendor Privacy Assessment & Due Diligence

Build a repeatable vendor assessment and due diligence workflow that validates privacy posture early: purpose, data categories, processing locations, transfer mechanisms, and vendor controls. Evidence-driven checks reduce surprises post-contract.

Vendor Selection & Privacy Criteria

Define selection criteria that prioritise privacy-by-design: data minimisation, residency options, encryption, access segregation, logging, and deletion guarantees. Require documentation on subprocessors, incident history, and independent attestations.

Privacy SLA Requirements

Translate privacy needs into measurable SLA requirements: DSAR support timelines, breach notification windows, log retention, evidence delivery for audits, and deletion/return timelines at contract end. Tie SLA penalties to privacy-impacting failures.

Data Processor vs Data Controller Roles

Clarify whether the vendor acts as processor or controller for each data flow. Role clarity aligns responsibilities for lawful basis, transparency, security measures, transfers, and responding to data subject requests.

Vendor Security & Privacy Audits

Request recent audits, certifications, and penetration tests; review remediation plans and variance logs. Where needed, perform focused assessments (secure development, access management, deletion verification) and document risk treatment.

DTIA (Data Transfer Impact Assessment) for GDPR

For GDPR-regulated processing with cross-border transfers, conduct a Data Transfer Impact Assessment (DTIA). Evaluate transfer tools (e.g., SCCs), destination law and practice, vendor technical/organisational measures (encryption, key control, access controls), and supplementary safeguards. Record conclusions and residual risk before enabling transfers.

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Data Processing Agreements (DPA)

Operationalise privacy obligations via a robust DPA that specifies processing scope, locations, confidentiality, security measures, assistance with rights requests, audit cooperation, and exit duties.

Contractual Privacy Obligations

Make contractual terms explicit: subprocessor approval, breach notification, assistance with DPIAs, deletion and evidence of destruction, and timely access to logs. Align obligations to your policies and regulatory triggers.

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Managing Vendor Access to Data

Control and monitor what vendors can see and do. Enforce least privilege, segregate environments, log administrative actions, and restrict exports. Require ticketed access with expiry and periodic access reviews.

Vendor Data Breach Response

Codify joint breach handling: immediate containment steps, notification timelines, evidence capture, and customer communications. Require vendors to run playbooks, preserve logs, and support your forensic process without delay.

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Ongoing Vendor Privacy Management

After go-live, sustain compliance with cadence-based reviews, change notifications, and automated controls that detect drift in processing, locations, and access.

Subprocessor Management

Maintain a current subprocessor list, review changes in advance, and assess downstream vendors for equivalent protections. Flow down contractual terms and verify technical safeguards at each tier.

Termination & Data Return Procedures

Plan the exit early. Define termination steps for data return or deletion, confirm formats and timelines, and require verifiable proof of destruction. Revoke credentials, retrieve keys where applicable, and remove residual data from caches, backups (as feasible), and test environments.

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• Risk-based vendor selection with privacy criteria and DTIA for cross-border transfers
• Contracted SLAs for DSARs, logging, breach notice, and deletion/return
• Controlled, audited vendor access with periodic reviews and export limits
• Ongoing oversight: subprocessor approvals, evidence refresh, and exit proof