How to Monitor Privacy and Security of Software Vendors? Practical Guide

Why is monitoring vendor privacy critical?

Contracting software is just the beginning. Privacy policies change, incidents happen, and terms of use are updated — often without prior notice or with communications that go unnoticed.

For Compliance, Legal, IT, and Procurement teams, these changes can represent significant regulatory, contractual, and reputational risks.

Continuous monitoring of vendor privacy and security isn't a luxury — it's a strategic necessity. Companies that master this process reduce exposure to incidents, avoid contractual mismatches, and anticipate policy change impacts before they become problems.

What happens when you don't monitor your vendors?

Three common scenarios that could be avoided:

Imagine receiving a data breach notification from a vendor you contracted two years ago. Your first reaction? Rush to review the contract and discover — too late — that incident notification clauses weren't clear or hadn't been updated since initial contracting.

Scenario 1: Silent policy change

A CRM vendor changes its data retention policy from 90 to 180 days without clear notification. Your Compliance team only discovers this when a data subject exercises deletion rights and receives a response incompatible with what was documented internally.

Scenario 2: Undeclared new AI use

An HR software your company has used for years implements AI functionalities for performance analysis. The change is buried in a terms of use update. Without monitoring, you only discover when an employee questions the transparency of evaluations.

Scenario 3: Public incident not communicated

A vendor suffers a breach affecting thousands of clients but doesn't send direct notification to your company. You discover through media when it's too late to mitigate internal impacts and provide clarifications to your own customers or employees.

What are the benefits of continuous monitoring?

Implementing a structured monitoring process brings tangible and measurable benefits:

Incident risk reduction

Anticipating policy changes allows adjusting internal controls before problems materialize. You're not caught off guard.

Contractual compliance

Changes in terms or policies can misalign what was contractually agreed. Monitoring enables triggering clause reviews or renegotiations when necessary.

Auditable evidence

Maintaining historical records of policy changes and incidents creates an auditable trail demonstrating continuous diligence in due diligence and third-party management processes.

Rapid response

When you monitor, you can act immediately. Whether to communicate to internal stakeholders, adjust processes, or question the vendor about uncommunicated changes.

How to structure an effective monitoring process?

Continuous monitoring doesn't need to be complex or manual. The secret lies in defining roles, sources, cadence, and triggers.

What is the ideal RACI for vendor monitoring?

RACI (Responsible, Accountable, Consulted, Informed) is fundamental to prevent monitoring from falling into limbo between areas.

Responsible (Executors):

DPO/Compliance: Monitors changes in privacy policies and personal data-related terms
IT/Security: Tracks release notes, security updates, and reported vulnerabilities
Procurement: Verifies contractual changes and SLA impacts

Accountable (Final responsible):

CISO or Head of Compliance: Defines monitoring strategy, approves escalations, and coordinates responses to critical incidents

Consulted (Consulted):

Legal: Evaluates contractual impacts of changes and guides on clauses to reinforce
Business areas (end users): Provide context on actual software use and operational impacts

Informed (Informed):

Executives (CIO, COO): Receive executive summaries of critical changes and relevant incidents
Risk committees: Are updated on changes impacting organization's risk posture

Which sources should be monitored?

Primary sources (essential):

Official privacy policies: Version published on vendor's website, with attention to update dates
Terms of use and SLA: Changes in responsibilities, data retention, and data subject rights
Trust centers: Many vendors maintain dedicated pages with information about security, compliance, and certifications
Release notes and changelogs: Product updates may include new functionalities impacting privacy (e.g., AI use)

Secondary sources (complementary):

Official email communications: Notifications sent by vendor — configure email rules to not miss them
Status and incident pages: Many SaaS have public status pages (e.g., status.vendor.com)
News and public alerts: Breaches or incidents may be disclosed in specialized media before official communication

What should be the monitoring cadence?

Frequency depends on vendor risk profile and criticality of processed data.

Weekly monitoring:

Critical vendors processing sensitive data (health, financial, HR)
Software with recent incident history

Monthly monitoring:

Medium-risk vendors (marketing, productivity, collaboration)
Software with stable policies and good reputation

Quarterly monitoring:

Low-risk vendors with low data volume
Tools with restricted use or limited scope

Triggers for immediate monitoring:

Incident notification received
Relevant regulatory change (e.g., new privacy law)
Acquisition or merger involving the vendor
Media alert about breach or investigation

How to record and document monitoring evidence?

Maintaining auditable records is essential to demonstrate diligence in internal, regulatory, or contractual audits.

What to document:

Verification date: When monitoring was performed
Source consulted: Policy URL, screenshot, email received
Identified changes: What changed compared to previous version
Impact analysis: Risk assessment of the change (critical, moderate, low)
Actions taken: Stakeholder communication, contractual review, control adjustments

Recommended tools:

Structured spreadsheets: For smaller teams, a spreadsheet with policy version history works well
Third-party risk management systems (TPRM): Specialized platforms allow centralizing monitoring and automations
Automated monitoring platforms: Services that track policy changes and send alerts (e.g., TrustThis)

How to integrate monitoring with Procurement, Legal, and IT?

Isolated monitoring loses effectiveness. Integration between areas ensures rapid and coordinated responses.

How should Procurement use monitoring?

Before contracting:

Require vendors to declare how they communicate policy changes
Include contractual clauses obligating prior notification of critical changes

During contract term:

Review monitoring reports before contract renewals
Use uncommunicated changes as negotiation leverage (e.g., demanding stricter clauses)

How should Legal use monitoring?

Contractual validation:

Compare contractual terms with updated public policies
Identify mismatches requiring contractual amendments

Incident management:

Use monitoring evidence to trigger liability clauses
Document change history for potential litigation or regulatory investigation

How should IT use monitoring?

Security and technical compliance:

Track release notes to identify new integrations, APIs, or functionalities impacting data
Review changes in subprocessors and cloud providers

Incident response:

Have visibility of public incidents to trigger internal contingency plans
Assess if disclosed vulnerabilities affect the specific configuration used by the company

What is automation's role in monitoring?

Manual monitoring is inefficient and prone to failures. Automation is the path to scale the process without compromising quality.

Automation benefits:

Broad coverage: Monitor hundreds of vendors simultaneously
Real-time alerts: Receive immediate notifications when changes are detected
Reduction of repetitive work: Free teams for impact analysis and decision-making
Centralized history: Maintain previous policy versions for comparison and audit

Tools and approaches:

Web scraping and page diff: Scripts that capture policy versions and identify differences
Vendor APIs: When available, provide structured data about updates
Specialized platforms: Services like TrustThis automate policy and incident monitoring based on public sources

TrustThis, for example, offers continuous monitoring with alerts for privacy policy changes and public incidents, allowing Compliance and IT teams to focus on analysis and response instead of manual tracking.

What are common mistakes when monitoring vendors?

Even with a defined process, some recurring errors compromise monitoring effectiveness.

Mistake 1: Monitoring only during contracting

Initial assessment is important, but without continuous follow-up, you lose sight of critical changes.

Mistake 2: Not defining clear responsible parties

Without RACI, monitoring becomes "everyone's" responsibility — and ends up being nobody's.

Mistake 3: Ignoring secondary sources

Relying only on official policy may cause you to miss communications in release notes or trust centers.

Mistake 4: Not documenting evidence

Without records, it's impossible to prove diligence in audits or demonstrate when changes occurred.

Mistake 5: Lack of integration between areas

Compliance identifies change but doesn't communicate to Procurement or Legal — result: no practical action is taken.

How to start monitoring your vendors today?

Step 1: List your critical vendors

Start with the 10-20 vendors that process the most sensitive data or are most critical to operations.

Step 2: Define roles and responsibilities

Create a clear RACI: who monitors, who decides, who is informed.

Step 3: Establish sources and cadence

Document which sources will be monitored and how frequently for each vendor.

Step 4: Configure alerts and automations

Use tools to automate change tracking and alert sending.

Step 5: Integrate with existing processes

Connect monitoring with renewal due diligence, incident management, and contractual reviews.

Step 6: Document and review periodically

Maintain auditable records and review the process quarterly for adjustments.

How does TrustThis facilitate continuous monitoring?

TrustThis automates vendor privacy and security monitoring based on public information, allowing you to:

Receive alerts for privacy policy and terms of use changes
Track public incidents and reported breaches
Compare historical policy versions to understand what changed
Generate executive reports with auditable evidence for Compliance and Legal

Continuous monitoring doesn't need to be manual, slow, or flawed. With clear processes and adequate tools, you transform vendor management into competitive advantage — reducing risks, strengthening compliance, and protecting your company's reputation.

SUGGESTED IMAGES FOR CONTENT:

Visual RACI diagram (Responsible, Accountable, Consulted, Informed) applied to vendor monitoring, with icons representing DPO, IT, Procurement, and Legal in their respective responsibilities

Illustration of monitoring sources: privacy policies, trust centers, release notes, and status pages organized as a triage funnel

Visual timeline comparing monitoring cadences (weekly, monthly, quarterly) with icons of different vendor types and their risk levels