Subprocessor Management

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
  
  
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Tips for doing it right

• Require vendors to maintain a public or shareable subprocessor list
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• 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
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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.

Additional resources

• GDPR Article 28: Requirements for processor contracts
• IAPP Guide to Third-Party Risk
• SOC 2 Trust Services Criteria — Vendor and subprocessor controls