GDPR Sub-Processor Authorization Form

Managing sub-processor relationships under GDPR Article 28 requires clear documentation of processing instructions, security measures, and accountability frameworks. This GDPR Sub-Processor Authorization Form helps data processors formalize sub-processing arrangements with proper legal safeguards, ensuring compliance with EU data protection regulations.

When a processor engages another processor (a sub-processor) to carry out specific processing activities on behalf of a controller, GDPR Article 28(4) mandates that this must be documented through a contract or legal act that imposes the same data protection obligations as those between the controller and the processor. This template streamlines that critical documentation process.

Designed for legal teams, data protection officers, compliance managers, and IT service providers, this form captures essential elements including the scope of processing activities, data categories, security requirements, international data transfers, breach notification procedures, and audit rights. Whether you're a SaaS provider engaging hosting services, a consultancy using third-party analytics tools, or any organization that needs to subcontract data processing activities, this template ensures you have the proper legal foundation.

Paperform makes GDPR compliance documentation straightforward with conditional logic that adapts questions based on processing scope, calculation fields for compliance scoring, and professional formatting that matches your organization's brand. You can embed this form directly into your vendor management portal or procurement workflow.

Once authorization is submitted, use Stepper to automate your compliance workflow—route approvals through your DPO and legal counsel, create records in your vendor management system, schedule periodic reviews, and trigger security assessment requests. Integration with tools like Airtable, Google Sheets, or your CRM means your sub-processor register stays current without manual data entry.

For organizations requiring executed agreements, Papersign enables you to convert form submissions into legally binding contracts with secure eSignatures from all parties—processor, sub-processor, and controller representatives—maintaining a complete audit trail for regulatory demonstration.

This template helps you maintain GDPR Article 28 compliance, demonstrate accountability under Article 5(2), and build trust with controllers by showing robust sub-processor governance. Whether you're processing personal data for hundreds of clients or managing a complex supply chain of service providers, this form creates the documentation backbone for lawful sub-processing arrangements.