When a customer asks “send your DPA + TOMs + sub‑processor list + contacts”, many teams start digging through inboxes. Build a small internal onboarding app that requests, versions, approves, and exports an evidence pack. That’s not just compliance — it’s sales speed.
Primary source (quick but real)
If a provider processes personal data on behalf of a controller, the processing must be governed by a contract meeting GDPR Art. 28 requirements. Security measures are covered by GDPR Art. 32.
Primary source:
- GDPR (Regulation (EU) 2016/679) on EUR‑Lex: https://eur-lex.europa.eu/eli/reg/2016/679/oj
Not legal advice. Loop in your privacy/legal team for your specific setup.
Pain/Case hook: the deal is blocked by paperwork
Typical 2026 reality:
- Procurement/IT wants an answer within 48–72 hours.
- Your docs are scattered across:
- old PDFs
- random SharePoint folders
- “ask Sarah, she has the latest”
Outcome:
- slow back‑and‑forth
- missed deadlines
- unnecessary risk debates
Fix: treat vendor onboarding as a repeatable product flow.
The minimal system: one inbox, one status, one audit trail
This is not a GRC project. It’s a reliability project.
The 80/20 building blocks:
- Request templates (DPA/TOMs/questionnaires) per customer type
- Document vault (versions, expiry dates, owners)
- Approval workflow (privacy/security/sales)
- Evidence pack export (bundle + changelog)
What the app should do (without overkill)
Roles & permissions
- Sales can trigger and track status
- Privacy/Security approves content
- “Approved” is truly approved (immutable or full history)
Automation
- expiry reminders (annual TOM refresh, certifications)
- sub‑processor changes: notify + approve
- generate the customer pack in one click
Transparency
- timestamps: who uploaded/changed/approved what
- status: Requested / In Review / Approved / Sent
Checklist 1: your baseline evidence pack
- DPA (Art. 28) with required clauses (scope, duration, purpose, categories, obligations)
- TOMs (Art. 32) document with version + date
- Sub‑processor list + change notification process
- Data flow summary (where data is processed/stored)
- Contacts (DPO/privacy, security, incident contact)
- Incident process (how to notify customers)
- Retention/deletion approach
Checklist 2: mini‑app spec (so it ships in 14 days)
- MUST: central vault + versioning
- MUST: status board per customer request
- MUST: approval step (privacy/security)
- MUST: export “customer evidence pack"
- SHOULD: expiry reminders + renewals
- SHOULD: templates per customer type
- NICE: auto‑redaction for sensitive details
- NICE: integrations (HubSpot, Jira, SharePoint, Google Drive)
A realistic 14‑day plan
- Days 1–2: inventory docs + define the templates
- Days 3–5: vault + versioning + owners + metadata
- Days 6–8: flow + roles/permissions + approvals
- Days 9–11: export pack + audit trail
- Days 12–14: reminders + SOP + a 1‑page sales playbook
CTA: we can build your vendor onboarding mini‑app
Send us:
- your top 3 recurring customer requests (DPA/TOMs/questionnaires)
- where your docs live today (Drive/SharePoint/Confluence)
- who approves (sales/privacy/security)
We’ll turn it into a small internal app that handles requests fast, clean, and auditably — without a GRC monster.