Sub-processor
A third party that processes data or performs work on the vendor's behalf as part of delivering the product, including offshore labeling or review teams, cloud hosts, and upstream model providers. Sub-processors are part of the system you are buying, so an undisclosed sub-processor is an undisclosed dependency and, often, an undisclosed data-handling and jurisdiction question.
Defined in 4 GAGE programs, which carry 5 distinct definitions of it. The wording above is taught in AI Governance: Applied Mastery.
How each discipline defines it
The same term does different work depending on who is using it. These are the definitions as each program teaches them, unedited.
A third party that processes data or performs work on the vendor's behalf as part of delivering the product, including offshore labeling or review teams, cloud hosts, and upstream model providers. Sub-processors are part of the system you are buying, so an undisclosed sub-processor is an undisclosed dependency and, often, an undisclosed data-handling and jurisdiction question.
A vendor or contractor engaged by an organization's primary vendor to perform part of a data-handling task, such as an annotation vendor that itself distributes labeling work to individual contractors. A due diligence process under GB/T 45674-2025 should account for this further layer, not only the primary vendor relationship.
A third party (such as a cloud hosting provider) that an AI vendor uses to help process user data, distinct from the vendor itself. Vendors that will not disclose their sub-processors present a specific gap in the vetting checklist's transparency requirements.
A third party the vendor uses to help deliver its service (for example, the cloud provider hosting their model), who may therefore also touch your data. Contracts should require you to know who they are and hold them to the same data terms.
A party a processor engages to help process data on the controller's behalf (for example a labeling subcontractor a data vendor uses). The controller must authorize sub-processors, which requires knowing they exist, so an unnamed or unauditable sub-processor is both a legal gap and a governance red flag.
Where it is taught
The exact lessons this term appears in. The first 7 topics of every program are free with a free account.
- Third-party data and the vendor claims you must verify yourself · Data Reality, AI Governance: Applied Mastery
- The vendor interrogation: questions that expose what the sales deck hides · Shipping AI and Surviving the Incident, AI Governance: Applied Mastery
- Vendor Management and Contracts · Technology, Platforms and Vendors, Business AI Transformation
Terms it appears with
Not an alphabetical neighbourhood: these are the terms taught in the same lessons, ranked by how often they appear together.