Do you disclose personal information to third parties only for the purpose(s) identified in the privacy notice or with the implicit or explicit consent of the individual?
Explanation
Limits on third-party disclosure are what this examines: whether you share personal information only for purposes named in your privacy notice or with the individual's consent. The disclosure aligns with purposes explicitly stated in your privacy notice/policy, OR
2. You have obtained consent (either implicit or explicit) from the individuals whose data is being shared.
In the context of a security assessment, this question evaluates your data privacy governance practices and compliance with privacy regulations like GDPR, CCPA, and others that require transparency about data sharing and user consent. The assessor wants to verify that you're not sharing personal data with third parties in ways that users haven't been informed about or haven't consented to.
This is important because unauthorized or undisclosed sharing of personal information can:
- Violate privacy regulations (resulting in fines and penalties)
- Breach user trust
- Create security risks if data is shared with entities that have inadequate security controls
To best answer this question, you should:
- Confirm your adherence to this principle
- Reference your privacy policy/notice and how it discloses third-party sharing
- Explain your consent mechanisms (how you obtain and track consent)
- Describe any processes that ensure third-party sharing aligns with stated purposes
- Mention any data processing agreements you have with third parties
Example Responses
Example Response 1
Yes, we strictly limit disclosure of personal information to third parties to only those purposes identified in our privacy notice Our privacy policy explicitly lists all categories of third parties we share data with and the specific purposes for such sharing We maintain a third-party data sharing register that is reviewed quarterly to ensure all sharing activities align with our privacy notices Before any new third-party data sharing arrangement is implemented, it undergoes a privacy impact assessment and legal review to verify alignment with our privacy notices Additionally, we obtain explicit consent through opt-in mechanisms when sharing data for purposes beyond what's necessary for our core services All third parties receiving personal data are bound by data processing agreements that restrict their use of the data to only the specified purposes.
Example Response 2
Yes, we only disclose personal information to third parties as outlined in our privacy notice or with appropriate consent Our privacy notice clearly states that we share certain user data with payment processors for transaction processing, analytics providers for service improvement, and cloud storage providers for secure data storage For any sharing beyond these core operational purposes, we implement a consent management platform that captures explicit user consent before sharing occurs Our Data Privacy Office conducts monthly audits of all data flows to third parties to ensure compliance with our stated purposes We maintain comprehensive records of consent and provide users with an easy-to-use privacy dashboard where they can review and modify their consent settings at any time.
Example Response 3
We generally try to limit sharing personal information with third parties, but we don't currently have a formal process to ensure all sharing aligns with our privacy notice Our privacy policy has broad language about potential third-party sharing, but it may not specifically enumerate all current third parties or purposes In some cases, our marketing department may share customer contact information with partners for promotional purposes without explicit consent, though users can opt-out afterward We're working to improve our practices by implementing a more detailed privacy notice, creating a third-party management program, and developing better consent mechanisms We expect these improvements to be in place within the next 6-9 months, at which point we'll be fully compliant with this requirement.
Context
- Tab
- Privacy
- Category
- Data Privacy
Related questions
- Have you performed a Data Privacy Impact Assesssment for the solution/project?
- Do you provide an end-user privacy notice about privacy policies and procedures that identify the purpose(s) for which personal information is collected, used, retained, and disclosed?
- Do you describe the choices available to the individual and obtain implicit or explicit consent with respect to the collection, use, and disclosure of personal information?
- Do you collect personal information only for the purpose(s) identified in the agreement with an institution or, if there is none, the purpose(s) identified in the privacy notice?
- Do you have a documented list of personal data your service maintains?
- Do you retain personal information for only as long as necessary to fulfill the stated purpose(s) or as required by law or regulation and thereafter appropriately dispose of such information?
