Should a security questionnaire for a processor be individually tailored to each data processing agreement or specific type of service?
ANSWER
There is no need for the questionnaire to be tailored each time to a specific agreement or specific type of service provided by a potential processor. On the one hand this would be time-consuming; on the other, it is doubtful whether it would be effective: while it is possible to assess in general terms which requirements should in principle be met by a given entity and which are worth asking about in the questionnaire, it is difficult to tailor questions perfectly to a given contractor.
The best approach appears to be to create several versions of a processor questionnaire, e.g. a detailed version (sent to entities providing IT solutions or payroll companies) and a simplified version (for entities to which data will be entrusted in a limited scope). The result of such a questionnaire could be reviewed by the DPO, who on that basis would decide whether the given entity provides adequate guarantees related to ensuring the security of personal data.


