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Cloud Controls Matrix
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DSP-13: Personal Data Sub-processing
Personal Data Sub-processing
DSP-13: Are processes, procedures, and technical measures defined, implemented, and evaluated for the transfer and sub-processing of personal data within the service supply chain (according to any applicable laws and regulations)?
The CSP should identify subcontractors and sub-processors that participate in the data processing, along with the chain of accountabilities and responsibilities used to ensure that data protection requirements are fulfilled.
The CSP should inform the cloud customer of any intended changes concerning the addition or replacement of subcontractors or sub-processors and allow the cloud customer to object to such changes or terminate the contract.
The data protection obligations agreed upon between the CSP and the cloud customer should be supported by any subcontractors or sub-processors used by the CSP.
The CSP remains liable to the cloud customer for data protection, regardless of whether the CSP uses subcontractors or not.
Control implemented
Not applicable - A “N/A” answer indicates that the portion of the control in question is out of scope of the assessment. The “SSRM control ownership” column is to be left blank (e.g., greyed out), and optionally the CSP may explain why it is the case (“CSP Implementation Description”).
No - A “No” answer indicates that the portion of the control in question is not implemented, while in scope of the assessment. The CSP has to assign the implementation responsibility of the control to the relevant party under column “SSRM control ownership”, and optionally elaborate on the “why” (has not been implemented), and “what” has to be done for its implementation by that party.
Yes - A “Yes” answer indicates that the portion of the control in question is implemented. The CSP indicates the responsible and accountable parties (SSRM control ownership), and optionally elaborates on the implementation “how-to” per relevant party CSP and/or CSC.
Control ownership
CSP-owned - The CSP is entirely responsible and accountable for the CCM control implementation.
CSC-owned - The Cloud Service Customer (CSC) is entirely responsible and accountable for the CCM control implementation.
Third-party - The third-party CSP in the supply chain (e.g., an IaaS provider) is responsible for CCM control implementation, while the CSP is fully accountable.
Shared CSP and CSC - Both the CSP and CSC share CCM control implementation responsibility and accountability.
Shared CSP and third party - Any CCM control implementation responsibility is shared between CSP and the third party, but the CSP remains fully accountable.
Description

Define, implement and evaluate processes, procedures and technical measures for the transfer and sub-processing of personal data within the service supply chain, according to any applicable laws and regulations.