Do you use sub-processors to process customer data? Please provide a list.
Explanation & Context
Explanation of the Question
This question is asking whether your organization engages third-party vendors or service providers (sub-processors) to handle customer data on your behalf. Essentially, it wants to know if you outsource any data processing tasks and, if so, which specific sub-processors you use. This is crucial because when you involve external entities in handling sensitive data, you extend your security responsibilities to ensure these sub-processors adhere to the same security standards as your organization.
Why It Matters
Understanding and disclosing the use of sub-processors is vital for several reasons. First, it helps maintain transparency with your customers about who has access to their data. Second, it ensures that all parties involved in data processing comply with relevant data protection regulations, such as GDPR or CCPA. Finally, it allows you to assess the security practices of these sub-processors, ensuring they meet your organization's security requirements and do not introduce vulnerabilities.
Example of Evidence
To demonstrate fulfillment of this question, you might provide a documented list of all sub-processors, including their names, the type of data they process, and the specific services they provide. Additionally, you could include contracts or agreements that outline the security obligations and compliance requirements these sub-processors must adhere to. Regular audits and assessments of these sub-processors’ security practices would further evidence your commitment to maintaining high security standards across your entire data processing ecosystem.
Example Responses
Example Response 1
We utilize Heroku as our primary platform-as-a-service (PaaS) provider for hosting our SaaS application. Additionally, we engage Stripe for payment processing and SendGrid for email delivery services. These sub-processors handle customer data in accordance with their respective data processing agreements, which outline stringent security and compliance requirements.
Example Response 2
Our SaaS application is hosted on Amazon Web Services (AWS), and we leverage several AWS services for data processing, including Amazon RDS for database management, Amazon S3 for storage, and AWS Lambda for serverless computing. Furthermore, we partner with third-party providers such as Twilio for communications and Datadog for monitoring and analytics. All sub-processors are contractually obligated to adhere to our security standards and undergo regular security assessments.
Example Response 3
As our software is exclusively deployed on-premises within our clients' environments, we do not engage sub-processors for processing customer data. Therefore, this question is not applicable to our operational model. However, we ensure that our on-premises infrastructure meets rigorous security standards and complies with relevant data protection regulations.

