Choose a subprocessor by first mapping the personal-data processing it will perform, then verifying that it offers sufficient guarantees for that specific work. Confirm your authorisation route and contractual protections, review security, transfer and operational evidence in proportion to risk, and document the decision and how changes will be reassessed. Under UK and EU GDPR frameworks, a processor’s assurance that a provider is “compliant” does not replace the controller’s assessment.
This guide focuses on UK and EU GDPR. Requirements can differ by jurisdiction, sector, contract and processing facts. The UK Information Commissioner’s Office (ICO) says its UK GDPR guidance is under review following the Data (Use and Access) Act, so check the current official guidance and applicable law before relying on this as legal advice.
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What should a subprocessor security checklist include?
A useful checklist connects the provider’s actual role and data access to its safeguards, contract terms and the risks to people. It should also establish who authorised the engagement, what evidence was reviewed, what remains uncertain, and when the decision must be revisited.
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- Map the proposed processing and its risks.
- Confirm the processor’s authority to engage the subprocessor and your own authorisation route.
- Assess the provider’s guarantees and evidence against the specific service.
- Check downstream contract terms, transfers, assistance, resilience and exit arrangements.
- Record the decision, conditions and review triggers.
The ICO says controllers should assess whether their processor is competent to process personal data in line with UK GDPR requirements. The European Data Protection Board (EDPB) says verification applies regardless of risk, but its extent should scale with the risks and the measures involved.
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Map the processing before reviewing the provider
Ask the internal service owner and the processor to describe the work precisely. A certificate or policy cannot show whether safeguards fit a service if you do not know what the service will do or what data it can reach.
- Roles and instructions: identify the controller, processor and proposed subprocessor, who gives instructions, and what each party is responsible for.
- Service and purpose: specify the service, its purpose and the activities the subprocessor will perform.
- People and data: identify data-subject categories, personal-data categories and sensitivity. Note whether special-category, criminal-offence, children’s, financial or other especially sensitive data are involved.
- Duration and access: record the processing period, systems involved, access paths and whether access is continuous or limited to support or maintenance.
- Locations and onward chain: identify where data is processed, the expected subprocessor chain and potential onward transfers.
- Change and termination: establish what happens if the service, provider or processing changes, and how data will be returned, exported or deleted when the service ends.
These particulars help determine what guarantees and technical and organisational measures are appropriate for the processing.
Confirm authorisation and contractual protections
Determine which authorisation model applies
The processor needs the controller’s prior written authorisation to engage a subprocessor. The arrangement may provide for specific written authorisation or general written authorisation.
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- General written authorisation: you approve a list or set of criteria. The processor must notify you of intended changes and give you an opportunity to object. Check that the notice process is workable: identify the notice method, timing, responsible contact, objection route and what happens while an objection is considered.
Keep the authorisation, relevant notice and any objection or conditions with the decision record. The applicable contract and law determine the details of the arrangement.
Check the contract chain
Review whether the controller–processor arrangement addresses the applicable Article 28 requirements. These include documented instructions, confidentiality, security, engagement of subprocessors, assistance with data-subject rights and controller obligations, return or deletion at the end of the contract, and audit and inspection rights.
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The processor–subprocessor contract must pass down the required data-protection obligations and provide an equivalent level of protection for the personal data. Under the ICO’s UK GDPR guidance, the processor remains liable to the controller for the subprocessor’s compliance with its obligations. Check that the terms cover the actual service and do not leave key protections dependent on informal assurances.
For EU arrangements, Commission Implementing Decision (EU) 2021/915 provides standard contractual clauses for controller–processor arrangements. Treat the clauses as a drafting resource to assess against the actual facts and governing law, not as a substitute for checking the provider and contract.
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Request evidence in proportion to the processing risk. The ICO identifies possible considerations such as relevant industry standards, technical expertise, capacity to assist the controller, privacy and information-security documentation, and adherence to a code of conduct or certification scheme. These are examples, not an exhaustive checklist or automatic pass/fail test.
Review safeguards that matter to this service
- Governance: security ownership, risk management and policies that cover the service being assessed.
- People and access: identity management, least-privilege access, privileged-account controls and personnel confidentiality.
- Data protection: encryption and pseudonymisation where appropriate to the data and processing.
- System security and resilience: safeguards for confidentiality, integrity, availability and resilience of processing systems.
- Recovery: backup, recovery and restoration of access to personal data after an incident.
- Testing: regular processes to test, assess and evaluate the effectiveness of security measures.
- Incident response: detection, escalation, investigation and practical support to the controller.
- Chain oversight: a current subprocessor inventory, oversight of further providers and a process for communicating changes.
- Transfers: processing locations and relevant transfer safeguards where data moves across borders.
- Controller assistance: support for individual rights requests, impact assessments and other applicable controller duties.
- Exit: data return, export and deletion at termination, including the treatment of backups where applicable.
Article 32 measures described by the ICO include, as appropriate, encryption or pseudonymisation; ongoing confidentiality, integrity, availability and resilience; restoration of access after an incident; and regular testing and assessment. What is appropriate depends on the processing and its risks.
Check assurance documents for fit
Do not treat a certificate or assurance report as proof that every relevant control is covered. Check its scope, exclusions, dates, independence and whether it covers the service, locations and systems that will handle your data. Where evidence is incomplete, stale, inaccurate or raises questions, ask targeted follow-ups and document the remaining uncertainty.
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How much verification is enough?
The EDPB’s Opinion 22/2024 says the controller’s verification obligation applies regardless of risk, while the extent of verification varies with the nature of the measures and the risk. A controller may use information supplied by its processor and build on it where necessary, including when it is incomplete or raises questions. Higher-risk processing warrants increased verification.
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The following evidence ladder is a practical way to organise a review; it is not a sequence mandated by the EDPB:
- Review current policies, service descriptions, data-flow information and security documentation.
- Check assurance reports, certificates or code adherence for scope, exclusions, dates and relevance to the actual service.
- Ask focused questions where documents do not cover the processing or leave a material issue unclear.
- For higher-risk work, consider deeper technical review, independent audit material or downstream contract review where needed to demonstrate compliance.
- Record evidence reviewed, gaps, mitigations, approver and review date.
Compare candidates using the same criteria
If more than one provider could perform the work, compare them against the same axes and weight those axes for the processing. A lower-risk service may need less evidence than a service involving highly sensitive data or extensive access, but the comparison should still be tied to the intended use.
| Comparison axis | Evidence to compare |
|---|---|
| Processing fit | Role clarity, service scope, purpose, data types, locations and ability to follow instructions. |
| Security | Relevant controls, assurance scope, incident handling, resilience and recovery. |
| Contract | Authorisation model, equivalent downstream obligations, assistance, audit and exit terms. |
| Transparency | Named subprocessors, current information, notice period and objection process. |
| Transfers | Countries, transfer mechanism, supporting documentation and supplementary safeguards where needed. |
| Operational support | Support for rights requests, breach response, impact assessments and cooperation with the controller. |
| Exit and continuity | Data return or export, deletion, service continuity and evidence of completion. |
| Evidence quality | Coverage, independence, recency, exclusions and fit to the service being assessed. |
Review international transfers based on the data flow
If personal data moves outside the European Economic Area, identify the transfer mechanism and assess the documentation and safeguards relevant to that transfer. The EDPB’s Opinion 22/2024 discusses documentation such as the transfer ground, a transfer impact assessment and possible supplementary measures in the circumstances it addresses.
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Apply the transfer rules for the relevant jurisdiction and the actual data flows. A provider’s location alone does not establish whether a restricted transfer occurs. Trace where data is accessed, stored and onward-transferred, then assess the mechanism and safeguards for those flows.
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Maintain readily available information identifying each processor and subprocessor, with enough detail to understand their roles in the processing chain. The EDPB says processors should proactively provide this information and keep it up to date.
Assign an owner to receive and assess change notices. Before a proposed change takes effect where the arrangement allows, assess the new provider’s role, data access, location, guarantees and contract flow-down. Record the outcome and update the inventory and risk assessment when the chain or processing changes.
Record a defensible decision
Use a decision record that another reviewer can understand without reconstructing the assessment from emails. Tailor it to the service and applicable law.
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- Processing purpose, data, subjects, duration and locations:
- Controller authorisation route and date:
- Risk level and reasons:
- Evidence reviewed, scope, dates and limitations:
- Security and privacy gaps and mitigations:
- Contract and downstream flow-down confirmed:
- Transfers and safeguards reviewed:
- Decision, owner, approver and date:
- Conditions, objection deadline or remediation actions:
- Next review trigger or date:
Reassess when the facts change
Subprocessor selection is an ongoing control, not a one-time procurement gate. Revisit the decision when the provider, service, purpose, data, access, location, transfer route or subprocessor chain changes, and when new evidence materially affects the assessment. Keep current identity and processing information and assign responsibility for checking notices and closing remediation actions.
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Frequently Asked Questions
Do I need to approve my processor’s subprocessors?
The processor needs your prior specific or general written authorisation. With general authorisation, the processor must notify you of intended changes and give you an opportunity to object; check your contract for the applicable process.
What should I ask a subprocessor?
Ask what service it performs, what personal data it can access, where and how it processes that data, what safeguards and assistance it provides, which further providers it uses, and how the contract addresses instructions, security, incidents, transfers and exit.
Do I need to request every subprocessing contract?
No general duty to request every such contract systematically is identified in the EDPB’s Opinion 22/2024. Decide case by case whether reviewing a particular downstream contract is needed to verify compliance and document the reason.
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