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Vendors, Data Intermediaries & Transfers

2 weeks 7 tasks Transfer Limitation · Protection · Accountability

This workshop brings the applications and vendors that process personal data under control: inventory, vendor assessments, contracts with data intermediaries, transfers outside Singapore and ongoing monitoring.

Workshop 10 video

Quick intro with a screen recording of the tasks — coming soon

What ResGuard provides

  • Vendor management with questionnaire templates for security and privacy assessments
  • AI-supported answers to speed up vendor assessments
  • Application inventory with hosting countries for transfer checks
  • Template for the data processing agreement

Workshop tasks

  1. 1. Application inventory

    List every application holding personal data, including cloud services: owner, deployment, hosting country and contract with the provider.

    In ResGuard: Applications
  2. 2. Vendor inventory

    Identify vendors with access to data using the recipients in the inventory, classify them (data intermediary or organisation) and rate their criticality.

    In ResGuard: Vendor Management
  3. 3. Vendor assessments

    Send security and privacy questionnaires to critical vendors, review certifications such as ISO 27001 or DPTM and record the result. ResGuard's AI can pre-fill the questionnaires.

    In ResGuard: Vendor Management
  4. 4. Data intermediary contracts

    Put a contract in place with every data intermediary: purpose, confidentiality, protection, retention, sub-contracting, breach reporting, and return or disposal of data.

  5. 5. Overseas transfers

    Identify where data is stored and accessed from, and document how a comparable standard of protection is ensured for each transfer.

    In ResGuard: Applications
  6. 6. Ongoing monitoring

    Assess new vendors before use, re-assess critical vendors every year and manage the exit when a contract ends.

    In ResGuard: Vendor Management
  7. 7. Workshop review & close-out

    Review the results, attach evidence and close the objective in ResGuard.

    In ResGuard: Objective Manager

What to keep in mind under the PDPA

  • The organisation stays responsible for personal data processed on its behalf by a data intermediary. Data intermediaries themselves must meet the Protection and Retention Limitation obligations and notify you of data breaches without undue delay.
  • Transfers outside Singapore need a comparable standard of protection, for example through contracts, binding corporate rules or certifications such as APEC CBPR or PRP.
  • Many cloud services host data outside Singapore: review them with particular care.

Expected result

  • Complete inventory of applications and vendors
  • Critical vendors assessed
  • Contracts with data intermediaries in place
  • Overseas transfers documented

ResGuard modules: Applications, Vendor Management, AI-supported vendor assessment

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