How to ensure vendors don’t store or sell data?

Protecting your subscriber data from vendor misuse starts with strong contractual provisions. Your Data Processing Agreement should explicitly prohibit the processor from using your data for their own purposes, selling or licensing data to third parties, retaining data beyond your instructions, or commingling your data with other customers' data for analytics or product improvement without your explicit authorization. These restrictions should survive contract termination. The uvendor can't use data after your relationship ends just because the DPA no longer applies.

Beyond contracts, conduct due diligence on vendor business models. Some vendors-particularly free or heavily discounted services-monetize through data rather than direct fees. Review their privacy policies, terms of service, and public statements about how they use customer data. Look for red flags like vague language about "improving services" with customer data, partnerships with data brokers, or acquisition by companies known for data monetization. If a vendor's business model doesn't clearly explain how they make money, your data might be the product.

Implement ongoing verification and audit practices. Exercise audit rights periodically (your DPA should grant these), or at minimum request updated compliance certifications and security assessments. Monitor for concerning changes in vendor policies, ownership, or public reputation. Use data loss prevention or monitoring tools where feasible to detect unauthorized data transfers. If you discover a vendor has misused data, act immediately-document the violation, consider terminating the relationship, and assess whether you have notification obligations to affected subscribers or regulators. Trust but verify-strong contracts are necessary but not sufficient; ongoing vigilance catches problems that paper agreements can't prevent.