Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / sub-processor-risk-analysis-memo.docx
sub-processor-risk-analysis-memo.docx
Parties
Harkness LLP
Vantage Mobility Systems Corp
Crane LLP
Pinehurst Cybersecurity Advisors LLC
Dates
November 10, 2022
August 5, 2022
June 15, 2022
January 1, 2022
September 14, 2022
September 28, 2022
October 7, 2022
October 21, 2022
November 4, 2022
November 15, 2022
Amounts
$6.5
$1.625
$19.5
$2.1
$4.8
$25,000
Obligations
From a risk perspective, the introduction of a sub-processor does not reduce the universe of applicable regulatory obligations — it expands the attack surface and the number of entities with access to potentially sensitive personal information, thereby compounding the risk profile that VMS must manage
Under the CCPA/CPRA framework, Cloudvault — as an entity that processes personal information on behalf of Meridian, which in turn processes personal information on behalf of VMS — must be contractually designated and bound as either a "service provider" or a "contractor" (as those terms are defined under Cal
• VMS must be prepared to respond to consent requests promptly
The sub-processor's processing of VMS data must be limited to the specific purpose and scope described in the DPA and the sub-processor's listing in Annex C
The sub-processor agreement must include confidentiality obligations binding on all sub-processor personnel who may have access to VMS data, including employees, contractors, and agents
The sub-processor must implement technical and organizational security measures at least equivalent to those specified in Annex B to the VMS-Meridian DPA