Do you perform privacy impact assesments of third parties that collect, process, or have access to personal data to ensure they meet industry and regulatory standards and to mitigate harmful, unethical, or discriminatory impacts on data subjects?
Explanation
Guidance
Privacy impact assessments ensure that third-party collection, processing, or access to personal data aligns with and supports your organization's own efforts and commitments to clients. This is particularly important when a specific third party operates from or is subject to a jurisdiction different from that of your organization.
Example Responses
Example Response 1
Yes, we conduct comprehensive privacy impact assessments for all third parties that collect, process, or access personal data Our assessment process includes a detailed questionnaire covering data collection practices, processing activities, security controls, and compliance with regulations like GDPR, CCPA, and industry standards We evaluate third parties before engagement and annually thereafter Our legal and privacy teams review all responses and may request additional documentation or conduct virtual/on-site assessments for high-risk vendors We require all third parties to sign Data Processing Agreements that include specific privacy and security requirements For international vendors, we conduct additional jurisdictional risk assessments and implement appropriate data transfer mechanisms (e.g., Standard Contractual Clauses) We maintain a risk register of findings and track remediation efforts Any vendor that fails to meet our privacy standards must implement corrective actions or face termination of the relationship.
Example Response 2
Yes, our organization implements a risk-based approach to third-party privacy impact assessments We categorize vendors based on the sensitivity and volume of personal data they access High-risk vendors undergo a comprehensive assessment including documentation review, technical interviews, and compliance verification against ISO 27701, NIST Privacy Framework, and applicable regulations Medium and low-risk vendors complete self-assessments that our privacy team reviews We conduct these assessments during onboarding and repeat them every 12-24 months depending on risk level Our assessment specifically evaluates algorithmic decision-making processes for potential discriminatory impacts and ethical concerns We maintain contractual clauses requiring vendors to notify us of any privacy incidents within 24 hours and cooperate in investigations For vendors in regions without adequate privacy protections, we implement additional contractual safeguards and monitoring Our Chief Privacy Officer reviews all assessment results and approves vendor relationships.
Example Response 3
No, we currently do not conduct formal privacy impact assessments of third parties While we do have standard security questionnaires that we send to vendors during the procurement process, these do not specifically focus on privacy practices or regulatory compliance We rely primarily on contractual terms in our vendor agreements that require compliance with applicable laws We recognize this is a gap in our privacy program and are developing a more comprehensive third-party privacy assessment framework Our planned approach will include formal privacy impact assessments for new and existing vendors, with implementation expected in the next 6-9 months In the interim, we are mitigating risk by limiting the personal data shared with third parties to only what is absolutely necessary for their services.
Context
- Tab
- Privacy
- Category
- Privacy of Third Parties
