A Data Fiduciary remains accountable for personal data even after handing it to a processor or sub-processor. That accountability doesn't transfer, which makes vendor risk a direct extension of your own compliance posture.
A data processing agreement that looks compliant on paper doesn't guarantee compliant practice. Assessments need to verify how vendors actually handle, store, and secure the data they're entrusted with.
A thorough review examines the vendor's security controls, sub-processor relationships, breach notification commitments, and data retention and deletion practices — not just their stated policies.
Vendor risk is not a one-time check at onboarding. Periodic re-assessment, especially for vendors handling sensitive personal data, keeps the compliance program aligned with how vendor practices evolve over time.