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Episode 28 — Govern external sharing: processors, controllers, recipients, and onward transfers

February 22, 2026 · 14 min

Show notes

This episode covers how to govern external sharing using clear role definitions and contractual controls, because CIPM questions regularly test whether you can classify parties correctly and apply the right oversight. You will review what it means operationally to share data with processors, other controllers, and various recipients, and how onward transfers and sub-processors can expand risk beyond what the business intended. We discuss due diligence, contract clauses, security and privacy requirements, and ongoing monitoring, including how to handle vendors that change their processing or add sub-processors midstream. Practical examples include marketing platforms, payment providers, cloud services, and support tooling, where data can be replicated and enriched quickly. Troubleshooting focuses on building a repeatable review and approval process, maintaining a defensible record of sharing decisions, and responding when a business unit wants to onboard a vendor without completing required privacy checks. Produced by BareMetalCyber.com, where you’ll find more cyber audio courses, books, and information to strengthen your educational path. Also, if you want to stay up to date with the latest news, visit DailyCyber.News for a newsletter you can use, and a daily podcast you can commute with.

All episodes of Certified: The IAPP CIPM Audio Course

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