Processor

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)

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

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.

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.

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

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.

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.