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Governance, Risk, Audit & Privacy · Intermediate

Sub-Processor

Processor engaged by another processor to carry out processing on behalf of a controller.

Definition

Under GDPR Article 28 a processor may engage a sub-processor only with the controller's prior specific or general written authorization, and must flow down the same data protection obligations. The original processor remains fully liable to the controller for the sub-processor's performance.

Example

A SaaS provider lists its cloud hosting and email delivery vendors as sub-processors.

Exam tip

Controllers commonly get notification and objection rights for new sub-processors.

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