Perceptyx Sub-Processors

 

Sub-Processors

Perceptyx uses certain sub-processors to assist in providing Perceptyx services. A sub-processor is a third party data processor engaged by Perceptyx who agrees to receive personal data from Perceptyx intended for processing activities necessary to support delivery of services. 

Perceptyx maintains an up-to-date list of the names and locations of all sub-processors, as seen below.

Third Party Sub-Processors

Entity Name

Sub Processing Activity

Entity Country

Amazon AWS Cloud compute servers, and storage for some customers. USA
Call Experts After-hour customer support. USA
Microsoft Azure Cloud provider, Cloud compute servers, and storage for some customers. USA
Microsoft Translator Machine translation of comments between languages. USA
OKTA IaaS IDP MFA SSO SAML provider. USA
Responsive Translation Services (Smartcat.ai) Human translation of survey questions, prior to survey launch to ensure nuanced and correct translations. USA
Twilio Sending text messages for launching surveys USA

 

What responsibilities and liabilities does Perceptyx have as processors for our clients?  

In addition to SCC and DPA contractual obligations to our clients, or the data controllers , Perceptyx is also held liable under GDPR. . If we fail to meet our obligations, or act outside or against the data controller’s instructions, we may be liable to pay damages in legal proceedings, or be subject to fines or other penalties or corrective measures.

As a data processor, we can  not engage a sub-processor’s services without the data controller’s prior specific or general written authorization in the SCC and DPA. Agreements must be amended anytime a new data processor is added. . To get authorization we as Perceptyx (the processor) must put in place a contract with the sub-processor. The terms of the contract that relate to Article 28(3) must offer an equivalent level of protection for the personal data as those in the contract between the controller and processor. We remain liable to the controller for the compliance of any sub-processors we engage.

How does Perceptyx select Sub-processors to support our service?

Any sub-processor that we choose must have the same level of controls that meet GDPR. Perceptyx ensures a proper vetting process to meet our strategic goals & values when we choose a new sub-processor. All sub-processors that we have chosen (AWS, Azure, and Okta) are well suited to meet the controls of GDPR.

When does Perceptyx communicate about sub-processors?

Sub-processors are shared during the initial signing of a new contract, renewal, or at any point a new sub-processor is added. Email communications are sent to our client partners of any pending changes, giving them the opportunity to comment. Any individual objections, comments, or needs will be supported by the Client Relationship Manager. This page will also continuously be updated with a current list of sub-processors and what they do for us.

We have no objections. Do we need to physically amend the agreements now?

If no objection within the 30-day window, agreement to the sub-processor additions is implied and no further action will need to be taken until time of contract renewal. If individual clients object or have immediate contract requirements, please reach out to your Client Relationship Manager for support.  It is recommended to update the agreements at the time of the renewal for customers that have agreed. 

Objecting to A Sub-Processor

Please submit your reasonable objection via this LINK. If you first have additional questions, please reach out to your Client Relationship Manager for further support.