DPA Review Pro

DPA Review Pro: practical plan

DPA diligence brief

Terms to confirm

Subprocessors: 10-day notice period; verify notification channel, objection rights, list access and flow-down obligations.

Incident notice: “Without undue delay” is undefined. Ask what operational target applies and what information will be provided as investigation develops.

• Deletion: 90 days after termination; clarify active systems, backups, legal retention and deletion confirmation.

Additional review areas

Confirm controller/processor roles, documented instructions, data categories, data-subject request support, audit evidence, confidentiality, security controls, international transfers and allocation of regulatory assistance.

Operational questions

Can the vendor identify all data locations and subprocessors? How are permissions revoked? What happens to exports and support tickets? How quickly can deletion be verified?

Diligence evidence

Request the current subprocessor list, security documentation, incident process, deletion standard and transfer mechanism. Compare with the main agreement and privacy notice.

Escalation

Send gaps to privacy counsel and security owners. This summary is not a legal interpretation; review the full executed documents before approval.

Measurement and review

Record the baseline, source, date range, denominator and owner. Use one primary measure plus quality guardrails; compare like-for-like cohorts and disclose missing data. Treat estimates as scenarios, not observed outcomes.

Risks and controls

Check relevance, consent, disclosure, workload and downside before scaling. Keep an evidence trail, obtain human review for material commitments, and pause if trust, quality or compliance signals deteriorate.

Next steps

1. Confirm the goal, audience and available capacity.
2. Gather the minimum evidence for a first test.
3. Assign an owner, budget and review date.
4. Run a small pilot, record outcomes and decide whether to iterate, expand or stop.