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Sub-processor

As explained in First-Party Data Activation

A third party engaged by a data processor to process personal data on behalf of the processor or its controller.

A sub-processor is a third party engaged by a data processor to process personal data for the processor or its controller. In generative marketing, an AI provider may become a sub-processor when it receives personally identifiable information (PII). section 9.3.4

Treating an AI service as a potential sub-processor creates practical governance obligations:

  • Consult compliance teams before adopting capabilities that send organizational data to third-party providers. section 9.3.4
  • Confirm that security and compliance teams accept the data shared with the service. section 9.3.4
  • Consult legal teams about privacy requirements and intellectual property generated by AI models. section 9.3.4

Generative marketing provider

A marketing capability that sends PII to OpenAI or Google Cloud may need to list the provider as a sub-processor and obtain security and compliance approval. section 9.3.4

How First-Party Data Activation covers it

How deep it goes
Defines the role and outlines compliance, security, and legal checks, but stops short of determining jurisdiction-specific legal status.
Examples
Names OpenAI and Google Cloud as third-party generative AI providers that may receive PII.
What it assumes
Assumes familiarity with PII, privacy regulations, organizational compliance, and third-party data services.
What you can do after
Evaluate whether an external AI provider requires sub-processor treatment and route the decision through security, compliance, and legal teams.
How it connects
Connects sub-processors with GDPR, PII, generative AI, data security, compliance, and intellectual property.
Cover of First-Party Data Activation
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This explainer was generated by Manning's knowledge graph from the text of First-Party Data Activation. The section links point to the parts of the book it draws on.