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 5 GAGE programs, which carry 6 distinct definitions of it. The wording above is taught in Certified AI Governance Professional (CAIGP).
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 processor engaged by another processor to carry out processing on the controller's behalf. The initial processor remains fully liable to the controller for its performance.
Where it is taught
The exact lessons this term appears in. The first module of every program is free with a free account.
- Third-party data and the vendor claims you must verify yourself · Data Reality, Certified AI Governance Professional (CAIGP)
- The vendor interrogation: questions that expose what the sales deck hides · Shipping AI and Surviving the Incident, Certified AI Governance Professional (CAIGP)
- Client Confidentiality and Compliance When AI Touches the Work · AI for Lobbying Productivity, The AI Lobbyist: Certified AI Policy Strategist
- Vendor Management and Contracts · Technology, Platforms and Vendors, Certified AI Transformation Professional (CATP)
- AI Data Security Standards · Data Security for AI, Certified China AI Regulatory Professional (CCARP)
- Vendor privacy and shared responsibility · Privacy and Data Governance, Certified Enterprise Governance, Risk and Compliance Professional (CEGP)
Where it shows up at work
A definition is where Sub-processor starts. The lessons above teach it inside the competencies below, which are what job descriptions ask for and what the GAGE credential records. Every link here is drawn from the same careers map that builds a role's readiness check.
Tiers vendors by use and impact, requests evidence instead of promises, tests in the customer's context, and plans monitoring and exit.
2 lessons on this page teach it as a primary outcome.
Turns controls into enforceable obligations: data use, change notice, audit rights, incident duties, subcontractors, IP, exit and deletion.
One lesson on this page teach it as a primary outcome.
Writes requirements, runs a fair evaluation, pilots within limits, and refuses a demo as evidence.
One lesson on this page teach it as a primary outcome.
Roles that hire for it
Each role page shows the full competency set, what the seat decides, and a readiness check against your own evidence.
- AI Vendor Risk Managerneeds it at depth
- Third-Party AI Risk Analystneeds it at depth
- Third-Party Cyber Risk Managerneeds it at depth
- Chief Information Officer, technology leadership editionneeds it at depth
- Chief Audit Executive, AI audit editionneeds working knowledge
- Chief Compliance Officer, AI compliance editionneeds working knowledge
How job descriptions say it
Postings rarely use the textbook word. These are the phrases the careers map reads as asking for the competencies above.
Where the frameworks place it: NIST AI RMF GOVERN 6 and MANAGE 3; ISO/IEC 42001 Annex A supplier controls; GDPR Article 28; EU AI Act value-chain obligations.
One interview question about it
A business unit wants to buy an AI tool next week. What do you ask the vendor, what evidence do you require, and what would make you say no?
Asked of candidates for ai vendor due diligence and third-party risk. Answering it in your own words is exactly how a GAGE topic is passed, and the credential records the pass where an employer can check it.
If you come from another field
Some backgrounds already carry this competency, and the readiness check gives credit for it.
- Privacy and data protection carries it as a claim to back up: Processor and vendor review is routine privacy work.
- Cybersecurity and IT carries it as a claim to back up: Supplier security assessment is routine.
- Nonprofit program and grants oversight carries it as a claim to back up: Reviewing grant and vendor agreements for data terms is vendor review.
Terms it appears with
Not an alphabetical neighbourhood: these are the terms taught in the same lessons, ranked by how often they appear together.