Subprocessor list template

A subprocessor list tells your customers which vendors process their personal data on your behalf, for what, and where.

Why customers ask for it

Under Art. 28(2) GDPR, a processor may only engage another processor with the controller's written authorisation. Where the authorisation is general, the processor must inform the controller of intended additions or replacements and give it the chance to object. A published list, plus a way to hear about changes, is a common way to do that.

Columns

The vendor columns are the tedious part. The vendor pages collect them with sources.

Example

The rows below are fictional and only show the format.

VendorPurposeCategories of personal dataData locationTransfer mechanismVendor DPADate added
Example Hosting Ltd (fictional)Application hostingAccount data, usage logsEU (Frankfurt)Not needed (EU only)https://example.com/dpa2026-01-15
Example Mail Inc (fictional)Transactional emailEmail addresses, namesUSSCCshttps://example.com/mail-dpa2026-03-02

Download

Rather start from your stack? Pick your vendors in the generator and the vendor columns are filled in for you.

Templates, not legal advice. Have your own counsel check anything you send to a customer.

A hosted version of your list

This would be a hosted subprocessor page that updates when a vendor changes and notifies your customers. It doesn't exist yet, so there is nothing to sign up for. I'm testing whether people want it. One question, no email address, no free text.

Which comes closest to why you'd want it?