SOC 2 P6.5: Vendor Privacy Commitments
Your vendors can be your biggest privacy liability. P6.5 requires you to obtain explicit privacy commitments from all third parties accessing personal information. Without documented agreements, you're exposed to regulatory risk and customer trust violations.
What this means
P6.5 mandates that your organization obtains contractual privacy commitments from vendors, service providers, and other third parties who access personal information on your behalf. These commitments must ensure third parties support your organization's privacy objectives and comply with applicable privacy laws. This goes beyond generic data processing agreements—you need explicit, documented promises that vendors will protect sensitive data according to your standards.
How to comply
- 1.Inventory all vendors and third parties with access to personal information
- 2.Develop a standard vendor privacy commitment template or addendum
- 3.Include specific privacy obligations: data protection, breach notification, permitted use restrictions, and confidentiality requirements
- 4.Obtain signed privacy commitments from all current and new vendors before granting data access
- 5.Document the commitment execution and maintenance in your vendor management records
- 6.Periodically review and renew vendor commitments to reflect changes in privacy regulations
Evidence auditors look for
- Signed Data Processing Agreements (DPAs) with privacy schedules
- Vendor contracts containing privacy commitment clauses
- Privacy addendums to existing vendor agreements
- Vendor assessment questionnaires documenting privacy controls
- Email confirmations from vendors acknowledging privacy obligations
- Master Service Agreements with embedded privacy commitments
- Vendor management register tracking privacy commitment status and renewal dates
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
GRCWatch automates vendor privacy commitment tracking by maintaining a central repository of executed agreements, alerting you to renewal deadlines, and generating audit-ready evidence of vendor privacy compliance status.
See how GRCWatch handles this control automatically
Start free trial