Skip to content

Glossary

Subprocessor

Short answer

A subprocessor is a third party engaged by a data processor to process personal data on behalf of the controller, for example a cloud host used by a software vendor. Under GDPR Article 28, the controller must authorize subprocessors in writing, and the processor stays fully liable for them.

By Pactinel editorial teamReviewed on October 22, 2026

If a customer uses a SaaS product, the vendor is the processor, and the vendor's hosting provider, email delivery service or support tool may be subprocessors.

What GDPR Article 28 says

  • The processor needs the controller's written authorization to engage another processor, either specific or general.
  • Under general authorization, the processor must inform the controller of intended additions or replacements and give it a chance to object.
  • The subprocessor must be bound by the same data protection obligations as the processor.
  • The original processor remains fully liable to the controller if the subprocessor fails to comply.

What a subprocessor list contains

ItemWhy it matters
Name and serviceIdentifies who handles the data
Country of processingTriggers transfer rules
Data categoriesShows the exposure
Date addedLets you see changes

Example

A vendor publishes its subprocessor list and promises 30 days' notice of additions. If a new subprocessor in a third country appears, the customer has the notice period to object. A reviewer should diarize that period.

See data processing agreement for the contract that sets these terms.

This is general information, not legal advice.

Sources

  1. GDPR Article 28 - Processor