In the context of Service Providers, the Third Parties section has this meaning: If your organization is a Service Provider to other organizations (meaning you process personal information for another party), you might have a requirement to keep a record of all Third Parties (your Clients) to whom you provide such services. This section enables you to maintain such a record and will update the Record of Processing Report. This section is NOT for organizations to whom you provide data subjects’ information.
The Third Parties section provides two tabs: Processing Categories and Third Parties. You may dismiss the introduction by clicking the ‘X’.
Processing Categories
Begin by creating Processing Categories, then add your Clients (Third Parties) and link them to processing categories.
Add New Processing Category
From the Processing Category tab, click Add New and the Edit Processing Category pop-up appears. Complete your entry following the guidelines on the pop-up. You may select one or more Countries. Once they are checked, click outside of the Countries dropdown, then choose Save.
After saving, the category automatically appears in your listing.
View Category listing
The category listing can be filtered by entering text into the search box. The search is applied to: Processing Category Name, Country. Filters are cleared by clicking the ‘X’ on the right of the search box.
You can sort the listing alphabetically ascending or descending by clicking on the heading for ‘Third Party Name’ or ‘Outside US’.
Edit Processing Category
To edit a category, click within the entry. The Edit Processing Category pop-up appears. Modify the entry and Save. Changes are automatically displayed on Third Parties using this category.
Delete Processing Category
Note: You cannot delete a category that is being used by a Third Party (Client).
To delete a category, click Delete to the right of the entry. Confirm the deletion on the pop-up by clicking OK.
Third Parties
Once your Processing Categories are created, you will create your Third Parties (Clients).
Add New Third Party
Adding Third Parties is found in the ‘Add New’ dropdown. You may capture their details individually (Add New) or perform a bulk upload (Import Clients) using the template provided (Client Import Template).
Add new Third Party manually
To add a Third Party, click ‘Add New’ from the dropdown.
On the pop-up, add your Third Party details. Save when your input is complete. These fields are required on a manual entry: NName, Email, Telephone, Country, Processing Categories.
After saving, your new manual entry appears in the client list.
Import Third Parties from CSV
You may perform a bulk upload of Third Parties using the CSV template provided.
From the ‘Add New’ dropdown, download the Third Party import csv. This downloads a CSV template file named ‘client.csv’.
Create the Third Party entries using your tool of choice. There are sample entries provided in the template; delete them before you upload. If you use a spreadsheet application like Excel, remember to Save As CSV. These fields are required on a CSV upload: Client name; Client country. For data completeness, we recommend you include data for more than the two required fields.
Note: If you include a Processing Category that does not exist, it will be created. If any categories are created via import, edit the category after import to include the missing information.
The following fields are included in the template.
- Client name – required field
- Client phone – optional; prefix with country code e.g., 1-
- Client email
- Client country – required field
- Client Representative name
- Representative email
- Representative phone – optional; prefix with country code e.g., 1-
- Client DPO name
- DPO email
- DPO phone – optional; prefix with country code e.g., 1-
- Processing category 1
- Processing category 2
- Processing category 3
- Processing category 4
- Processing category 5
From the ‘Add New’ dropdown, upload your completed CSV file using ‘Import clients’.
After a successful upload, your third party listing will refresh with the new entries added.
TIP: If you do not see a progress bar or new entries after uploading, you may need to refresh your web page when doing multiple uploads after another.
Upload/Download Third Party Contract
After you have a signed contract, upload the contract. You can only have one contract per client.
A file named “Company1-contract-2024.pdf” appears with an internal file name in the ‘Agreement’ column. You can also download the current contract by clicking on the internal file name. You cannot delete a contract once it has been uploaded.
WARNING: When you upload a new contract, the previous contract is removed and replaced with the most recent upload. The previous contract cannot be recovered.
TIP: If you would like to retain expired/old contracts in DPDx, upload a copy into the “Notes and files” section for the client. For visibility and easy access, we also recommend you keep the current contract with the client profile using the Upload feature.
View Third Party listing
The client listing can be filtered by entering text into the search box. The search is applied to: Third Party Name, Country, Processing Categories. Filters are cleared by clicking the ‘X’ on the right of the search box.
You can sort the listing alphabetically ascending or descending by clicking on the heading for ‘Third Party Name’ or ‘Country’.
Edit Third Party
Click ‘Edit’ on the right of the third party listing to modify the vendor’s profile.
The Edit screen provides two tabs: Details; Notes and files
Details
The Details tab allows you to add and edit client information. Click Save when your updates are complete.
Notes and files
If you have notes and files that are relevant to this client, you will add them here.
Notes
Users can add custom notes about a client and the contract. Notes cannot be changed or deleted.
Files
Supporting files and documentation may be uploaded. A file named “Company1-contract-2023-EXPIRED.pdf” appears with an internal file name. After a file is uploaded, a description may be added or the file may be deleted. You can automatically download a File by clicking on the internal file name.
Delete Third Party
Before deleting a Third Party verify the following:
- Download the most recent contract if you need a local copy
- Download any files attached to the client
- Though you cannot download notes, you can copy and paste them into a local document if you need to preserve them.
To delete, click Delete to the right of the entry. On the confirmation pop-up, click OK.
We recommend creating business processes to manage your Third Party client list. An inactive Third Party will still appear in your Record of Processing Report as if you are actively receiving data. Check with your legal counsel for guidance.
