Subprocessor

A subprocessor is a third party a data processor uses to handle personal data: the cloud host, the LLM provider behind an AI feature, the transcription engine inside a meeting tool. DPAs require vendors to disclose subprocessors and flow down equivalent obligations.

AI products are chains: a writing tool may route prompts to two model providers on separate infrastructure. "Does the vendor train on my data" has to be asked down the chain — the subprocessor list is where the answer actually lives.