Subprocessor change notice
How to tell customers you added or replaced a vendor
When a company starts or stops handling customer data, send a short note. Name the vendor, what it does, what data it touches, where it processes, and the date the change takes effect.
This is a practical note for a security review, not legal advice.
What the notice should name
A customer should be able to see what changed without opening a second document.
- VendorUse the company name a customer will recognize.
- What it doesSay the job it performs with customer data, such as hosting, email, or support.
- What dataName the customer data it will receive, store, or be able to read.
- Where it processesName the country or region when you know it, and say so when you do not.
- Effective dateGive the date the change starts, or the date a vendor stops.
If the vendor's own page does not name a place, say that you do not know it yet. Do not guess a country.
An email you can paste
Send this from your own mail. Edit the brackets, and delete any line that is not true.
If you are replacing a vendor, name the company that is stopping and the company that is starting. If you are removing a vendor, say it stops on that date, and name anything that takes its place.
Subject: We are adding [Vendor] on [effective date]
Hello,
We are adding [Vendor] to the companies that handle customer data for [product].
[Vendor] will [what it does]. It will receive [the customer data it will see]. It processes that data in [country or region]. This starts on [effective date].
The current list is at [link].
Any notice period, and any way to object, is in our agreement with you: [agreement name]. Please reply to this email if you have a question.
[Your name]
[Company]
The number of days is in your agreement
A notice period, and any window to object, usually sits in your contract with that customer, or in the data processing agreement you signed with them.
Open that agreement and use the clause that is there. Write a number of days only when the contract states one. There is no universal number of days to paste in.
If the agreement says nothing about notice, say so. Do not promise a window you cannot point to. If the clause is unclear, ask a lawyer.
Keep a record of who you told
After you send the email, write down who received it and the date you sent it. A line is enough: the customer, the address you used, the date, and which vendor the note was about.
Keep that line in your own mail, or in the document where you keep the review. If a customer objects, keep the objection and your reply in that same place.
What saving a row does
Saving a row updates the public vendor list and the date on that row. That date is the day you saved the row. It is the day you last checked the company, what it does, where processing happens, and the agreement link.
That date is not the effective date in your email, and it is not a record of who you told. The row can hold the company, what it does, where processing happens, a link to the agreement, and that date. It does not hold the kind of data you named in the email.
Once the page is public, Trust Prep also adds a dated entry to the Change history on your page when you add or remove a vendor, or change what it does, its name, or where it processes. A changed agreement link alone is not logged. Entries are newest first, and you can delete one made by mistake. Automatic vendor history starts only after the page is public. A note you add yourself can be saved before publishing and appears when the page is public.
The page can also carry a short note called How we notify you, up to 400 characters, with its own last updated date. You write it in the Changes section of the editor. The editor offers suggested wording, and nothing is published until you save it. The note tells a reviewer what you do. It does not send anything.
Trust Prep does not email customers, does not track objections, and does not send notices. The email, and who received it, stay in your own mail.
If you want the longer notes
How to answer the question about how customers hear of a change is in the security review guide.
How to answer the change row on a questionnaire without SOC 2 is in the security questionnaire guide.
A table you can keep current, with the columns a reviewer expects, is in the subprocessor list template.
How soon you tell the customer about an incident is a different clock. What to write on that row is in the incident notification guide.
Related guides
Optional next step: a living page
The email above is enough for the change in front of you.
If you want one link for the list, Trust Prep publishes that vendor list as a page you edit when a company changes. Saving a row updates the public list and the date on that row. Once the page is public, the page also keeps a dated change history and can show a How we notify you note you write, so a reviewer can see what changed and how you tell customers. Reviewers open a public link made from your company name, without an account. They can copy the table or download the spreadsheet there. You can fill in the list and preview the page before you pay to publish the link. Publishing turns on after we confirm your payment.
Trust Prep does not email customers, does not track objections, and does not send notices. The email, and who received it, stay in your own mail.