DPAI-04
Standard
Weight: 5

Third-Party AI in Data Processing

Plain English Explanation

This question uncovers whether your data might encounter AI through the back door—via third-party services your vendor uses. For example, if your vendor uses a cloud storage provider, email service, or analytics platform that employs AI, your data could be processed by AI even if your primary vendor doesn't directly use it. It's about understanding the full journey your data takes and all the AI it might encounter along the way.

Business Impact

Hidden AI processing through subprocessors creates blind spots in your risk management. You might comply with AI governance policies with your direct vendor while unknowingly violating them through their supply chain. This can result in surprise audit failures, unexpected data exposure to AI training, or regulatory non-compliance. Understanding the complete AI touchpoint chain helps you assess true risk, negotiate appropriate protections, and maintain compliance across your entire vendor ecosystem.

Common Pitfalls

Companies frequently focus only on their direct vendor's AI use, missing that common services like customer support platforms, cloud infrastructure, or payment processors might use AI. Another mistake is accepting 'our subprocessors follow industry standards' without specific confirmation about AI usage and data handling practices.

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Question Information

Category
Data Privacy - AI/ML
Question ID
DPAI-04
Version
4.1.0
Importance
Standard
Weight
5/10

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