Has anyone experienced a controller exercising their right to object to addition of a new subprocessor by the processor? If so, what was the reason and how did it go down?

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Never encountered it. I imagine it might matter to very large regulated companies that have very specific requirements and compliance teams that go deep into supply chain reviews of sub vendors.

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What is their objection? Your agreement should state they cannot unreasonably withhold consent for a sub….ask for a sound explanation for their reasoning

Clarification- this isn’t my current situation. I draft/negotiate a ton of DPAs but have never seen this provision actually enforced. Was just curious how it plays out in a real life situation.

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Haven’t seen it but I suspect an objection would be if a sub doesn’t have sufficient info security standards-

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