Sharing & Disclosure · Company practice
Sub-processors receive User data; the current list is on Entrust's site
Entrust says it will need to share personal data about the Customer's Users with third-party service providers (“sub-processors”) in connection with providing the Onfido Identity Services. For the current list of sub-processors, the notice directs readers to https://www.entrust.com/legal-compliance/data-privacy/sub-processors.
Details
- Who
- Entrust
- What it does
- will need to share personal data with sub-processors
- Why
- provision of the Onfido Identity Services to Customers
Supporting quotations
Entrust will need to share personal data relating to the Customer’s Users with third party service providers (“sub-processors”) in connection with the provision of the Onfido Identity Services to Customers.
For the current list of sub-processors, visit https://www.entrust.com/legal-compliance/data-privacy/sub-processors.
Qualifications & exceptions
- The sharing described is in connection with providing the services.
Not stated here
- The linked sub-processor list is not supplied, so the identities, locations and functions of the sub-processors are unknown here.
Cross-references
Sharing & Disclosure · Company commitment
Cross-border transfers rely on adequacy or standard contractual clauses
Sharing personal data with a sub-processor may involve a cross-border transfer. Entrust says it makes cross-border transfers in accordance with relevant data privacy law requirements. Its example: for personal data transferred outside the EEA, it ensures an adequate level of protection by requiring sub-processors to enter into the European Commission-approved Standard Contractual Clauses (and/or their UK and Switzerland equivalents) if they are not in a country with an adequacy decision and there is no alternative transfer safeguard.
Details
- Where
- EEA, UK and Switzerland (clauses and equivalents named)
- Condition
- no adequacy decision and no alternative transfer safeguard
Supporting quotations
Entrust will need to share personal data relating to the Customer’s Users with third party service providers (“sub-processors”) in connection with the provision of the Onfido Identity Services to Customers.
The sharing of personal data with a sub-processor may involve the cross-border transfer of personal data. Entrust makes cross-border transfers of personal data in accordance with relevant data privacy law requirements. For example, we ensure that personal data that is transferred outside of the EEA benefits from an adequate level of protection by requiring sub-processors to enter into the European Commission approved Standard Contractual Clauses (and/or their UK and Switzerland equivalents) if they are not in a country that has the benefit of an adequacy decision and if there is no alternative transfer safeguard.
Qualifications & exceptions
- The stated safeguard is an example for transfers outside the EEA.
- The clauses are required only where there is no adequacy decision and no alternative safeguard.
Not stated here
- The notice does not identify the destination countries, the sub-processors or which safeguard applies to a particular transfer.
Cross-references