Assess and control what third-party services do with personal data you send them, before and after integration. Use when adding a vendor, SDK, or API that will receive user data.
Scanned 9/5/2026
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---
name: vendor-data-processing
description: Assess and control what third-party services do with personal data you send them, before and after integration. Use when adding a vendor, SDK, or API that will receive user data.
---
# Vendor data processing
Every integration extends your data perimeter to someone else's
systems. The vendor's controls become your controls, their breach
becomes your notification obligation, and their subprocessors become
part of your data map.
## Method
1. **Establish what the vendor actually receives.** Not what the
integration is for, but what the payload contains, including
identifiers, IP addresses, and anything incidental in free text or
logs (see data-minimization).
2. **Check purpose limits.** Whether the vendor may use your data to
improve their own products, train models, or build profiles is the
question that most often surprises teams after signing.
3. **Enumerate subprocessors and locations.** The vendor's own vendors
process your data too, and their regions matter (see
cross-border-transfers).
4. **Confirm deletion and export paths before integrating.** How you
get data out and how you make them delete it decides whether you can
honour your own obligations (see right-to-erasure,
subject-access-requests).
5. **Scope credentials and access narrowly.** Least privilege for the
vendor's key, restricted endpoints, and revocation you can perform
yourself in minutes (see secrets-management, api-security).
6. **Re-review on change.** SDK updates widen collection, terms change,
and subprocessor lists grow, so periodic re-checks catch drift that
the original assessment cannot.
## Boundaries
- Contractual terms are legal instruments; engineering verifies what
the integration does technically, which is often narrower or wider
than the contract describes.
- A vendor's certification is evidence, not a guarantee, and it does
not transfer your accountability to them.
- Client-side SDKs can collect far more than the documented API
suggests; inspect traffic rather than trusting the description.
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