GDPR Vendor Management & Third Party Privacy Risk Assessment
The GDPR requires businesses collecting data, defined as controllers, to put an appropriate agreement in place with the companies receiving data from it, whether they are a related organization or a third-party processor of the data. Businesses may only share data with organizations that provide sufficient guarantees to implement appropriate technical and organizational measures to meet the GDPR requirements and ensure the protection of EU citizens rights.
A key challenge for any organization is keeping track of all vendors and managing the points of access they have into your information assets. As marketing, product development and IT teams partner with various third parties to deliver their respective key business objectives, privacy and legal teams must be fully embedded and aware of the impact of such third parties. In addition, many new software, app and website features rely on third-party or open source software, APIs and libraries, increasing the challenges of monitoring everyone who may be receiving data.
In addition, for those organizations preparing for GDPR, Processor due diligence is a key obligation within GDPR and specifically under Article 28. Controllers can only partner with those Processors that provide “sufficient guarantees to implement appropriate technical and organizational measures” to carry out GDPR obligations, thereby raising the importance of third party management to a whole new level. Privacy, compliance and audit teams need full, real time visibility into all the third parties that access their information assets in order to properly protect the organization and its consumers.
Why Do Businesses Need to Engage in Vendor Risk Management?
Third-party vendors are a high risk area for privacy breaches. Third party service providers and other vendors have been identified in general as a substantial cybersecurity risk for some time. Since at least 2013 when hackers gained access to approximately 40 million debit and credit cards through a vendor, cybersecurity professionals have recognized the threat.
Third-parties also pose potential risks in the protection of the confidentiality of personal information from improper usage and sharing as well. One need not look any farther than Facebook, which gave access to information about its users to third-party app developers and saw that usage become highly controversial three years later with Cambridge Analytica. Organizations need to be carefully weighing the value of third-party vendor risks against the benefit of the services that they provide.
Organizations provide third-party providers with personal information in a variety of manners. Some do so intentionally by specifically giving the information to the third-party. Others do so in effect by placing the vendor in a situation where they have access to the information. Organizations may also share information unintentionally with a vendor. For example, an organization may have authorized a provider to pull information from the API but not realized that additional information could be accessed from the API.
Organizations may be restricted by their contract in their use of the personal information that they are provided or have access to through their work. However, the controller needs to have confidence that the third-party is respecting the terms of the agreement. One way to do so is to audit their data practices.
Contact Clarip Today for Help with CCPA and GPDR
The Clarip team and data privacy software are prepared to help your organization improve its privacy practices. Click here to contact us (return messages within 24 hours) or call 1-888-252-5653 to schedule a demo or speak to a member of the Clarip team.
If your challenge right now is CCPA compliance for your California operations, allow us to show you our CCPA software. From consent management software to offer the option to opt-out of the sale of personal data, to a powerful DSAR Portal to facilitate the right to access and delete, Clarip offers enterprise privacy management at an affordable price.
If you are preparing your European operations for GDPR compliance, we can help through our modular GDPR software. Whether you are looking to start the process with GDPR data mapping software, increase automation in your privacy program with DPIA software, or handle ePrivacy with a cookie consent manager, Clarip has the privacy platform that you need to bolster your program.
Click here to contact us (return messages within 24 hours) or call 1-888-252-5653 to schedule a demo and speak to a member of the Clarip team.
Related Content
GDPR Vendor Management & Third Party Privacy Risk Assessment
Risk and Control Self Assessment Framework for Privacy
Vendor Audit Process
Service Providers and the CCPA Right to Opt Out
GDPR Data Processing Agreement under Article 28
What is a Data Processor under GDPR?
Differences between a GDPR Data Controller vs. Data Processor