A vendor review should answer a simple question: what new data movement and dependency will this service create? Security questionnaires and contract templates are useful, but they work best after the product team can describe the intended integration.
Define the minimum data scope
List the fields the vendor needs, the purpose of each field and whether the integration can operate with less. Include prompts, attachments, support content and metadata—not only database columns. Identify data relating to employees, customers and users separately because the operational owners may differ.
Ask whether the vendor uses customer data to train or improve general models or services, and whether those uses can be disabled contractually and technically. Record the answer and source rather than relying on a sales call summary.
Map location and access
Record primary hosting locations, backup locations, support access and subprocessor access. “Region selected” may describe storage while global support or engineering access creates additional transfers. The relevant legal analysis depends on the applicable regimes and facts, so the inventory should expose all known routes.
Review the contract and live settings together
Compare the DPA, security terms, retention policy and product settings. Look for administrator controls, deletion behavior, audit logs, export, account termination and subprocessor notification. If the contract offers a control, confirm who enables and monitors it.
Ask for evidence proportional to risk
Higher-risk processing may justify more detailed security and privacy evidence. Useful evidence can include current audit reports, certification scope, penetration-test summaries, encryption design, incident history and business-continuity material. Check the entity and service covered by each document.
Evidence has an expiry date. Record when it was reviewed and assign an owner for renewal. An approval based on an old report should not silently remain current.
Plan for incidents and exit
Identify the internal person who receives a vendor incident notice and the downstream customers who may need information. Test whether essential logs and contact routes are available outside the affected vendor.
For exit, document export formats, deletion timing, backup treatment and any manual steps. Consider what happens if the vendor changes terms, removes a feature or becomes unavailable. This is both legal preparation and operational resilience.
Keep the decision record short
A useful vendor decision record includes the proposed use, data and people involved, locations and subprocessors, contract links, evidence reviewed, controls required before launch, accepted residual issues, reviewer and review date. It should not claim that a vendor is “fully compliant.” It should make the basis and limits of the decision visible.
For a cross-border product, this record can feed a wider PIPL or GDPR review and prevent the same facts from being reconstructed during every customer negotiation.
Sources
Editorial note: This guide is designed to support issue preparation. Applicable requirements depend on the facts, entities, markets and current law.