Secure Your Digital Supply Chain and Sub-processor Networks
Your compliance is only as strong as your weakest vendor. We build scalable third-party risk management programmes to audit, contract, and monitor your sub-processors and tools.
Vendor Defence
The Hidden Risks in Your Vendor Ecosystem
Modern organisations rely on dozens of third-party tools, cloud platforms, and API integrations. Without structured governance, each vendor represents a potential compliance and security liability.
Sub-processor Sprawl
Modern software companies use dozens of API tools, cloud hosts, and analytic suites. Tracing and controlling where your data goes is complex but critical for regulatory compliance.
Flawed Data Processing Agreements
Using generic vendor contracts without verified, custom Data Processing Agreements (DPAs) can expose your company to massive compliance risks and joint liability under GDPR Article 28.
US Vendor Schrems II Liability
Using US-based SaaS platforms without proper Standard Contractual Clauses (SCCs) or certified security frameworks introduces severe compliance and legal risks for European operations.
End-to-End Vendor Risk Management
Automated Vendor Risk Scoring
Set up clear, repeatable risk frameworks to quickly evaluate the privacy, security, and compliance posture of any vendor before onboarding.
DPA Negotiation & Review
We review and negotiate Data Processing Agreements (DPAs) with your vendors to ensure they protect your business and allocate liability correctly.
Sub-processor Inventories
Build and maintain accurate public lists of sub-processors to meet GDPR transparency rules and satisfy enterprise procurement requirements.
Continuous Audit Loops
Schedule and automate annual compliance reviews for your critical tech partners, data hosts, and third-party API providers.
Procurement Integration
Embed security and privacy reviews directly into your current procurement and purchasing workflows to prevent non-compliant tools from entering your stack.
The Vendor Governance Lifecycle
Our structured, four-phase approach transforms ad-hoc vendor management into a defensible, repeatable governance programme.
Vendor Discovery & Mapping
We map your entire digital supply chain — every SaaS tool, cloud host, analytics suite, and API integration — to create a complete inventory of your data processing relationships.
Risk Assessment & Scoring
Each vendor is evaluated against our proprietary risk matrix covering data access levels, geographic location, security certifications, and processing scope to assign a clear risk tier.
Contractual Hardening
We review, draft, and negotiate custom Data Processing Agreements (DPAs), Standard Contractual Clauses (SCCs), and liability frameworks to protect your organisation legally.
Continuous Monitoring
We establish automated audit schedules, vendor change notifications, and annual compliance reviews to ensure your supply chain stays defensible as your tech stack evolves.
Vendor Governance Deep-Dive
What is a Data Processing Agreement (DPA)? expand_more
A Data Processing Agreement (DPA) is a legally binding contract between a data controller and a data processor that outlines how the processor must protect and handle personal data. Under GDPR Article 28, it is mandatory to have a DPA in place with every vendor that processes personal data on your behalf.
Path reviews and negotiates DPAs with your vendors to ensure they contain the correct data processing limits, security commitments, sub-processor controls, and liability allocations to protect your organisation.
How do we handle US-based SaaS vendors after the Data Privacy Framework? expand_more
We verify whether the US vendor is certified under the EU-US Data Privacy Framework (DPF). If they are, this provides a valid legal basis for data transfers. However, relying solely on DPF certification carries risk due to ongoing legal challenges.
For vendors without DPF certification, or as a precautionary measure, we put in place custom Standard Contractual Clauses (SCCs) and complete a formal Transfer Impact Assessment (TIA) to guarantee your data transfers remain legally robust.
How often should we audit our sub-processors? expand_more
High-risk vendors that handle sensitive customer data, personal health information, or financial records should be audited at least annually. Lower-risk tools should be reviewed whenever their contract terms change, they introduce new processing activities, or they add new sub-processors.
Path establishes automated audit schedules and vendor change-notification systems to ensure you never miss a critical review window.
What happens if a vendor experiences a data breach? expand_more
Under GDPR Article 28, your organisation can be held jointly liable if a sub-processor experiences a breach and your vendor onboarding records, contracts, and risk audits are found to be deficient. This makes proactive vendor governance a critical business defence.
Path ensures your DPAs include clear breach notification obligations, indemnity provisions, and incident response coordination protocols so you are never caught unprepared.
Can you integrate vendor risk checks into our existing procurement workflow? expand_more
Yes. We design privacy and security checkpoints that integrate directly into your existing purchasing and procurement processes. Before any new tool or vendor is onboarded, it passes through a structured risk assessment that evaluates data access, geographic risk, and contractual adequacy.
This prevents non-compliant vendors from entering your technology stack and ensures every new tool meets your organisation's governance standards from day one.