Assess access: What should the employer revisit first?
A new subprocessor changes the dependency chain, requiring review of access, accountability, monitoring, and incidents.
The question
An employer uses a vendor’s internal assistant for employee policy questions. The vendor proposes a new subprocessor to host conversation logs in another service; the intended use is unchanged. What should the employer revisit first?
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- Reapprove the employee purpose and affected workforce.The purpose and workforce are unchanged, so this does not address the new processing dependency.
- Assess access, responsibilities, monitoring, and incident coordination. ✓The new subprocessor changes who can access logs and how accountability, monitoring, and incident response must operate.
- Reassess the assistant’s response quality and training benchmark.Those controls concern model performance, not the new provider’s access, responsibilities, monitoring, or incidents.
- Review the subprocessor’s data access and contractual responsibilities.These are important, but the review must also cover monitoring and incident coordination for the changed dependency chain.
The trap
A changed supplier chain can require reassessment even when the intended use remains stable. How to remember it
A new subprocessor changes the dependency chain, requiring review of access, accountability, monitoring, and incidents.
How many of these would you get right?
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