Content library
General Data Protection Regulation
28. Data processor

Requirement description

How to fill the requirement

General Data Protection Regulation

28. Data processor

Task name
Priority
Status
Theme
Policy
Other requirements
Data system listing and owner assignment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system management
53
requirements

Examples of other requirements this task affects

I06: Pääsyoikeuksien hallinnointi
Katakri
13 §: Tietoaineistojen ja tietojärjestelmien tietoturvallisuus
TiHL
24. Responsibility of the controller
GDPR
5. Principles relating to processing of personal data
GDPR
32. Security of processing
GDPR
See all related requirements and other information from tasks own page.
Go to >
Data system listing and owner assignment
1. Task description

Organisation must maintain a listing of used data systems and their owners. Owner is responsible for completing the related documentation and possible other security actions directly related to the data system.

Data system documentation must include at least:

  • System purpose and linked responsibilities
  • System's data location (covered in a separate task)
  • System's maintenance and development responsibilities and linked partners (covered in a separate task)
  • When necessary system's access roles and authentication methods (covered in a separate task)
  • When necessary systems interfaces to other systems (covered in a separate task)
Data processing partner listing and owner assignment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Partner management
Agreements and monitoring
43
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
44. General principle for transfers
GDPR
26. Joint controllers
GDPR
15.1.1: Information security policy for supplier relationships
ISO 27001
8.1.1: Inventory of assets
ISO 27001
See all related requirements and other information from tasks own page.
Go to >
Data processing partner listing and owner assignment
1. Task description

The organization must maintain a list of partners who have access to confidential information. System vendors and processors of personal data are listed separately from other stakeholders because they play an active role in the processing of data.

Documentation of partner contract status
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Partner management
Agreements and monitoring
26
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
15.1.3: Information and communication technology supply chain
ISO 27001
A.7.2.6: Contracts with PII processors
ISO 27701
HAL-16.1: Hankintojen turvallisuus - sopimukset
Julkri
TSU-04: Henkilötietojen käsittelijä
Julkri
See all related requirements and other information from tasks own page.
Go to >
Documentation of partner contract status
1. Task description

A supplier agreement will be drawn up with all partners directly or indirectly involved in the processing of data. The aim is to ensure that there is no misunderstanding between the organization and the supplier of parties' obligations regarding to complying with security requirements.

The organization shall include in the supplier agreement, as appropriate:

  • the data used by the supplier (and possible data classification) and staff receiving access to data
  • rules on the acceptable use of data
  • confidentiality requirements for data processing staff
  • parties responsibilities in meeting regulatory requirements
  • parties' concrete responsibilities in relation to data security (e.g. access control, monitoring)
  • reporting and correcting incidents
  • requirements for the use of subcontractors
  • allowing auditing supplier processes and controls related to the contract (and committing to correcting non-conformities)
  • a commitment to return or destroy data at the end of the contract
  • the supplier's responsibility to comply with organization's security guidelines
Inventory and documentation of data processing agreements
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
16
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
15.1.2: Addressing security within supplier agreements
ISO 27001
13.2.2: Agreements on information transfer
ISO 27001
A.8.2.4: Infringing instruction
ISO 27701
5.14: Information transfer
ISO 27001
See all related requirements and other information from tasks own page.
Go to >
Inventory and documentation of data processing agreements
1. Task description

The processors of personal data (e.g. providers of data systems, other partners using our employee or customer data) and the agreements related to the processing of personal data have been documented. The documentation includes e.g.:

  • Processor name and location
  • Purpose of processing data
  • Status of agreement
Documentation of data disclosures for data stores
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
10
requirements

Examples of other requirements this task affects

30. Records of processing activities
GDPR
28. Data processor
GDPR
12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
A.6.2: Recording of PII disclosures
ISO 27018
A.7.3.7: PII controllers' obligations to inform third parties
ISO 27701
See all related requirements and other information from tasks own page.
Go to >
Documentation of data disclosures for data stores
1. Task description

The data in a data store are, in principle, only available to that controller and under the same responsibility. If you pass data on to another organization for other use, you must clearly inform about it and state e.g. the recipient of the transfer and the legal basis.

Data processing agreement analysis for most important system providers
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system procurement
17
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
15.1.2: Addressing security within supplier agreements
ISO 27001
14.1.1: Information security requirements analysis and specification
ISO 27001
HAL-16.1: Hankintojen turvallisuus - sopimukset
Julkri
TSU-04.1: Henkilötietojen käsittelijä - Sopimukset
Julkri
See all related requirements and other information from tasks own page.
Go to >
Data processing agreement analysis for most important system providers
1. Task description

The processing agreement binds the actions of the data processor (such as the system vendor).

It can be important for us to ensure an important partner takes responsibility of e.g. access control (logging) and data recovery at the end of the contract according to our preferred policies.

Evaluation of data processing agreement for important data processors
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Partner management
Agreements and monitoring
7
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
15.1.2: Addressing security within supplier agreements
ISO 27001
TSU-04.1: Henkilötietojen käsittelijä - Sopimukset
Julkri
5.20: Addressing information security within supplier agreements
ISO 27001
P6.5: Notification of unauthorized disclosure of personal information from third parties
SOC 2
See all related requirements and other information from tasks own page.
Go to >
Evaluation of data processing agreement for important data processors
1. Task description

Data processing agreements bind the actions of a personal data processing partner.

It can be important for us to require an important partner to take care of e.g. ensuring the confidentiality requirements for its personnel and restricting the use of other processors of personal data in connection with our data.

Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
No items found.

Never duplicate effort. Do it once - improve compliance across frameworks.

Reach multi-framework compliance in the simplest possible way
Security frameworks tend to share the same core requirements - like risk management, backup, malware, personnel awareness or access management.
Cyberday maps all frameworks’ requirements into shared tasks - one single plan that improves all frameworks’ compliance.
Do it once - we automatically apply it to all current and future frameworks.
Get to know Cyberday
Start your free trial
Cyberday is your all-in-one solution for building a secure and compliant organization. Whether you're setting up a cyber security plan, evaluating policies, implementing tasks, or generating automated reports, Cyberday simplifies the entire process.
With AI-driven insights and a user-friendly interface, it's easier than ever to stay ahead of compliance requirements and focus on continuous improvement.
Clear framework compliance plans
Activate relevant frameworks and turn them into actionable policies tailored to your needs.
Credible reports to proof your compliance
Use guided tasks to ensure secure implementations and create professional reports with just a few clicks.
AI-powered improvement suggestions
Focus on the most impactful improvements in your compliance with help from Cyberday AI.