← NDPA 2023 · Controller obligations

s.29 — Data processor engagement

critical vendor-managementthird-party

Requirement

Where a data controller engages a data processor (or a processor engages another), it shall take reasonable measures, including a written agreement, to ensure the processor complies with the Act's principles, assists with data subject rights, implements appropriate security measures, provides information needed to demonstrate compliance, and notifies the controller of any sub-processor it engages (s.29).

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
processorsub-processorsubprocessorvendorthird party
Required element 2 — any one of
written contractagreementdpadata processing agreement
Supporting terms — specificity signals
section 29instructions onlysecurity obligationsassistauthorisationdelete on terminationaudit rightregister
Contradiction markers

Finding any of these outranks coverage — a policy that admits the gap is worse than silence.

no data processing agreement no written contract

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.28 Processors and processing agreements vendor-management third-party
CCPA/CPRA 1798.100(d) Contracts with service providers, contractors and third parties vendor-management third-party
SOC 2 CC9.2 Vendor and business partner risk management vendor-management third-party
ISO 27001 A.5.19 Information security in supplier relationships vendor-management third-party
PCI DSS 4.0.1 12.8 Third-party service provider management vendor-management third-party
HIPAA 164.308(b)(1) Business associate contracts (R) vendor-management third-party
GLBA 314.4(f) Oversight of service providers vendor-management third-party
NIST CSF 2.0 GV.SC-03 Supply chain risk management is integrated vendor-management third-party