Vendor Management

The organizational process of selecting, onboarding, monitoring, and governing third-party vendors who provide services or products to the organization, particularly those involving access to or processing of personal data. Effective privacy-focused vendor management includes: pre-engagement due diligence assessing vendors' privacy and security practices, risk classification based on data sensitivity and processing activities, contractual protections including data processing agreements and security requirements, onboarding procedures establishing access controls and training, ongoing monitoring of vendor compliance and security posture, incident response coordination for vendor-related breaches, and offboarding procedures ensuring data return or destruction. Organizations should: maintain comprehensive vendor inventories, categorize vendors by risk level, conduct security questionnaires and assessments, require relevant certifications (SOC 2, ISO 27001), establish audit rights, monitor vendor breaches and incidents, review and update vendor agreements periodically, and maintain termination rights for serious violations. Since organizations remain liable for vendor processing of their data, robust vendor management is essential for privacy compliance and risk mitigation.