Subprocessor Management
Best Practices
Dec 8, 2025
What is subprocessor management?
Subprocessor management is the process of identifying, monitoring, and approving the third parties (aka subprocessors) that your vendors rely on to deliver their services — especially when those subprocessors process your company’s or your customers’ data.
Think of it as vendor management for your vendors.
Why it matters
You’re responsible for your vendors — and their vendors. If a vendor uses an external service (like AWS or a support outsourcing firm) to process your data, you’re on the hook for it under most data privacy frameworks.
Subprocessor management helps you:
Stay compliant with GDPR, CCPA, HIPAA, and SOC 2
Maintain a complete picture of your data exposure
Avoid blind spots that create downstream risk
Respond quickly to audits and security assessments
What’s included in good subprocessor management?
Tracking which vendors use subprocessors
Knowing what data is processed and why
Approving new subprocessors (especially for sensitive data)
Getting notifications when vendors add or change subprocessors
Keeping a record of all subprocessors used across your vendor stack
Tips for doing it right
Require vendors to maintain a public or shareable subprocessor list
Include subprocessor approval language in your Data Processing Agreements (DPAs)
Use your vendor intake process to flag when subprocessors are involved
Regularly review subprocessor disclosures as part of risk assessments
How BRM can help
BRM’s AI SuperAgents can keep track of all publicly available subprocessor information for each one of your vendors. So, when one of your vendors makes changes, you can find that information in BRM.
To learn more about agentic compliance information gathering and verification with BRM, check out our compliance page.
Or, take a look at an interactive product demo, click here.
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