What is a sub-processor?
A sub-processor is a third-party data processor engaged by AARP Foundation SCSEP. The sub-processor has or potentially will get access to personal data that AARP Foundation SCSEP processes on behalf of its customers.
Why and how should I assess this?
If you choose to use AARP Foundation SCSEP as a processor, the sub-processors listed will have access to personal data processed on your behalf. When you assess the sub-processors of your vendors, you need to ensure the following:
A signed data processing agreement
You need to have a signed contract in place that commits AARP Foundation SCSEP to only use sub-processors with your permission.
Transfers of data out of Europe
If AARP Foundation SCSEP uses a sub-processor located outside Europe, there must be a legal basis for the transfer.