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LiveChat Legal: How to Build an Efficient and Well-Maintained Subprocessor List
As you probably know, transparency in data processing is a must right now. GDPR and other privacy-related regulations require companies to inform who can access different sets of data. Because of this obligation, you’ve most likely heard about subprocessors.
Maybe you’ve even had a chance to search for subprocessors after choosing software to include in your business’s processes. Or, perhaps you’ve had to create a subprocessor list for your own company. Regardless of your business model, keep reading, and you’ll find some good tips and updates about subprocessors.
1. Who are subprocessors?
To outline what we mean by a subprocessor list, let’s start with what entities qualify as subprocessors. If you share data (especially personal information) with anyone, this entity becomes your processor or subprocessor. Simply speaking, if you purchase a tool, for example, LiveChat, you use our service to deliver support or customer service to your webpage visitors. Therefore, we process data on your behalf, so, then, we’re your processor. The company using LiveChat is the data controller, LiveChat is a processor, and the tools that we use are subprocessors
2. Subprocessors and tools: How and what to check before you purchase a tool
3. I have a business and I need to create a list of subprocessors. How do I start?
If you have an online product, online shop, or just simply run a webpage, you may need to create your own list of subprocessors. It is required by GDPR to let people access that information.
To create a well-maintained subprocessor list, try to keep it clear and simple. Focus on the point of having it. Is it to provide information to your customers or to show what tools you use? Or, maybe you need to display what entities you cooperate with.
You may also want to present your policy. Briefly describe the set of rules you use when you choose your subprocessors and the guarantees you apply to maintain high quality. For example, you might mention that you have Data Processing Agreements signed with your subprocessors and that you always include modal clauses in them.
When it comes to the organization of your subprocessor list, the only limit is your creativity. You can have it as a simple bullet-point list, or, if you wish to include more info like company location or webpage, it will be handy to create a special form. Remember, the key here is that the list should be accessible and up to date.
4. I want to create a list of subprocessors. How should I organize it?
There are different approaches to this topic and, actually, there is no one good approach. It’s up to your business and it also depends on the number of subprocessors you have. If you feel that your list is too long or you have a complex business model, try to split it into categories. Need some inspiration? Check out the proposed split of categories below:
- By the category or type of processors: communication tools, support tools, payment processors, etc.
- By the group it applies to: customers, partners, employees, resellers, etc. This is especially useful when different processors apply to different groups.
- According to the time a subprocessor was added: you can track when you added a processor to your business flow.
5. How often do I have to update it?
As mentioned before, the subprocessor list needs to be up to date. Try to include all the changes a little bit before you start using a new subprocessor. You’ll appreciate this when you browse through the subprocessor list of the tools you use.
6. Do I have to add LiveChat to my list of subprocessors?
Yes, you should. If you use LiveChat on your webpage, most likely we process your data, so you should include us in your subprocessor list.