Vendor Data Transfer Review Agent

Vendors that handle personal data can move it to other countries and subprocessors without the company noticing. When a vendor review is triggered, this agent reads the data processing agreement and checks the required terms, such as breach notice, audit rights and deletion at end of contract. It identifies where data will go, including subprocessors and countries, and whether transfer safeguards are in place. It drafts a transfer risk assessment for countries without adequacy and reviews the vendor's security documents. If terms or documents are missing, it drafts requests to the vendor and reviews again when they arrive. The DPO approves the arrangement before data flows. Edge case: the vendor adds a subprocessor in a new country mid-contract, which triggers a fresh review.