Managing your privacy supply chain: Perils and pitfalls
Using processors requires risk assessments and ongoing monitoring. By Claire Saunders and Jenai Nissim of HelloDPO Law Ltd.
Processor management is not a new topic by any means, but it is one that raises its head on a reasonably regular basis, and over the years, some recurring themes have come to light which are worth discussing. From timing to co-ordination and risk assessment, there are plenty of perils and pitfalls for the unwary.
Not assigning responsibility for the process
If you are not clear about the who, what, when and how of processor onboarding and management, this can lead to a fragmented approach and the risk that due diligence and incorporating data protection terms are overlooked or that there is no consistent process to follow.
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