Requirement
The entity obtains commitments from vendors and other third parties with access to personal information to notify the entity in the event of actual or suspected unauthorized disclosures of personal information. Such notifications are reported to appropriate personnel and acted on in accordance with established incident-response procedures to meet the entity’s objectives related to privacy.
Points of Focus
Remediates Misuse of Personal Information by a Third Party [P][C]
Requirement: The entity takes remedial action in response to misuse of personal information by a third party to whom the entity has transferred such information.
Reports Actual or Suspected Unauthorized Disclosures [P][C]
Requirement: A process exists for obtaining commitments from vendors and other third parties to report to the entity actual or suspected unauthorized disclosures of personal information.
Explanation
When vendors handle personal data on the entity's behalf, contracts must require them to report any actual or suspected unauthorized disclosure, and those reports must feed the entity's incident-response process. Auditors check vendor agreements for notification clauses and evidence that received notifications were escalated and handled.
