Do all sub-processors maintain equivalent security and privacy controls to your own?
Explanation & Context
Explanation of the Question:
This question is asking whether the third-party service providers (sub-processors) that your organization uses also have the same level of security and privacy measures in place as your organization does. Essentially, it’s about ensuring that any external entities handling your data are just as committed to protecting it as you are. This is crucial because weak links in the security chain can lead to breaches, regardless of how secure your own systems are.
Why It Matters and Practical Example:
Ensuring that sub-processors maintain equivalent security and privacy controls helps protect your data from unauthorized access, breaches, and other security incidents. For example, if your organization uses a cloud storage provider, you need to confirm that this provider has robust encryption, regular security audits, and strict access controls similar to what you have implemented.
Example of Evidence:
To demonstrate fulfillment of this requirement, you might provide documentation such as security assessment reports, compliance certificates (like ISO 27001), or contracts with sub-processors that explicitly state they must adhere to the same security standards as your organization. Regular audits and reviews of these sub-processors’ security practices can also serve as evidence that they maintain equivalent controls.
Example Responses
Example Response 1
All our sub-processors, including our PaaS provider Vercel, are required to maintain security and privacy controls equivalent to our own, as stipulated in our contracts and confirmed through their compliance certifications such as SOC 2.
Example Response 2
Our sub-processors, which include AWS for hosting and various security tools integrated into our AWS environment, are contractually obligated to uphold security and privacy standards equivalent to ours, demonstrated through regular audits, compliance with ISO 27001, and SOC 2 Type II certifications.
Example Response 3
As our software is exclusively on-premises and does not rely on sub-processors for data handling or storage, this question is not applicable to our operational model.
