When I started looking into how to build a third-party risk program that actually made sense for privacy, I figured something would already exist. A guide, a framework, something practical.
It did not.
Most of what I found was security-heavy. Certifications, technical checklists, contracts. Privacy, if it showed up at all, was usually buried at the bottom with a one-line question about whether PII or PHI was involved. If the answer was no, the review moved on.
The problem is that even privacy lawyers have to pause before answering that question. Definitions vary, and context matters. So how are employees with no privacy background supposed to get it right? They are forced to make judgment calls on something that even experts debate.
Sometimes someone will even try to turn a DPIA into a vendor assessment form. That sounds efficient, but it creates its own set of problems. I will break that down in my next article.
Privacy risk definitely is not something you can squeeze in at the end. And most TPRM programs are not built to handle it.
Where Things Break
A lot of companies rely on SOC 2 reports or penetration testing reports and assume that is enough. If a vendor says they are compliant, the conversation moves on.
But those same vendors are collecting personal data, transferring it internationally, bringing in sub-processors, and using the data in ways that do not always get disclosed. And no one is really asking the privacy questions. Not early enough, not clearly enough, and not consistently.
That is the gap I kept running into, and why I started writing.
Privacy Risk Is Not Just a Checkbox
It is not something that fits under security or legal. It is its own thing. And it touches way more than people think.
It changes how you scope vendors. What you ask them. When you get involved. And what you can actually enforce later if something goes wrong.
But in most organizations, privacy teams get brought in too late, or not at all. By then, the vendor is already signed. Or live. Or both.
What I Am Working On
I am writing a book about building privacy-first third-party risk programs. Something that actually reflects how privacy works in the real world, not just how it is supposed to work on paper.
The book is still in progress. But as I write, I am putting together a framework based on real decisions teams are making and the questions that actually matter when it comes to vendors and data.
I am also thinking about building out some tools and templates to go with it. Things I wish I had when I was trying to piece this all together. If that is something you would want to see, let me know in the comments. I am still figuring out what is most useful.
Privacy risk cannot be stapled on at the end. It has to be part of how vendor relationships are built from the beginning, not just in assessments, but in contracts too.
It is important to evaluate those risks early and work closely with the commercial legal team reviewing contracts. That is how you make sure the right protections are in place.