SOC 2 (2017 TSC) P6.4 — Third-Party Privacy Commitments

What this control requires

The entity obtains privacy commitments from vendors and other third parties who have access to personal information to meet the entity's objectives related to privacy. The entity assesses those parties' compliance on a periodic and as-needed basis and takes corrective action, if necessary.

In plain English

The entity obtains privacy commitments from vendors and other third parties who have access to personal information to meet the entity's objectives related to privacy. In practice, this means you can prove you information objectives-level controls on a defined cadence.

Why it matters

Every SOC 2 audit opinion is built control-by-control from the Trust Services Criteria. A missing or failing criterion produces an exception in the report, which buyers, partners and procurement teams read line-by-line during vendor reviews.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A SOC 2 auditor (under AT-C §§ 105/205) tests both design and operating effectiveness over the audit window. For each criterion they expect a written control, a control owner, a population of events, and a sample tested against the population — including remediation tickets for exceptions.

Within Privacy, the assessor will trace your implementation back to the catalogue reference (Criterion P6.4) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Information. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Access. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Vendor. Document the trigger, the owner and the cadence.
• Scope: objectives, management, privacy commitments.

Evidence to collect

• Vendor Risk Management. vendor_risk_management evidence
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Third-party risk management evidence (assessments, contracts, due diligence) shows supplier oversight. Focus: Third-Party Privacy Commitments.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• BSI C5:2020 OIS-03 — Interfaces and Dependencies
• ISO/IEC 27001:2022 A.5.20 — Addressing information security within supplier agreements
• GDPR Article 76 — Confidentiality
• NIST SP 800-53 Rev. 5 PL-8(2) — Supplier Diversity
• CIS Controls v8 9.1 — Ensure Use of Only Fully Supported Browsers and Email Clients

Related controls in SOC 2 (2017 TSC)

• Criterion P6.1 — Third-Party Disclosure with Data Subject Consent
• Criterion P6.5 — Third-Party Breach Notification Commitments
• Criterion CC9.2 — Vendor Risk Management
• Criterion P3.1 — Personal Information Collection Aligned with Privacy Objectives
• Criterion P1.1 — Privacy Notice to Data Subjects
• Criterion P6.2 — Recordkeeping of Authorized Personal Information Disclosures

References

• AICPA / ASEC — SOC 2 (2017 TSC)
• Catalogue identifier: Criterion P6.4

Topics: vendor riskvendor managementprivacy managementsupply chain securitythird party monitoring