What is a sub-processor?
A sub-processor is a Vendor or Tool and Third Party which you use to offer your services when acting as a processor. You can think of these as sub-contractors or sub-contracted software you use to deliver your service.
You can find more examples and information about sub-processors here.
Adding a sub-processor
Add the Vendor or Tool and Third Party to your inventory. Follow these steps.
Go to Processes and select the process attached to your Vendor or Tool and Third Party. In our example, Processes > Authenticating Users.
Ensure the Legal Responsibility for the relevant process / processes is set to Processor. If not, change and save changes using the button on the upper-right corner.
If the Vendor or Tool and Third Party, as well as the process, are not missing any information, only the Vendor or Tool and Third Party will appear in your Privacy Policy and both will be listed on your Record of Processing Activities (ROPA).
⚠️ Note: The process will not appear in your Privacy Policy if you are marked as a Processor, as the Privacy Policy only shows processes for which you are a Controller.
If you have a linked Data Processing Agreement for which you are a processor, the Vendor should appear as a sub-processor.
Ensure you click Update > Regenerate on the document to reflect the changes.
Important: Disclaimer on Uploaded Documents
If you download a document generated by the platform, for example a DPA, make changes, and re-upload it, the document will no longer automatically update with the information stored on the platform.
Any updates made on the platform will not reflect in the re-uploaded document.