PRIV- 8 Authorized Agents

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What is this control about?

Implementing the control for ‘Authorized Agents’ is important to ensure that data access requests from individuals or entities acting on behalf of data subjects are properly authenticated and managed. Authorized agents are individuals or entities that have been granted legal authority to act on behalf of a data subject to submit data access requests and exercise their privacy rights. These authorized agents may include attorneys, legal representatives, or designated individuals authorized by the data subject.

By having a control in place to handle authorized agents, organizations can verify the legitimacy of these requests and ensure that sensitive information is only disclosed to individuals who have proper authorization. This control helps protect the privacy and rights of data subjects, as it prevents unauthorized individuals from gaining access to personal information without proper consent.

Compliance with data protection regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), often requires organizations to honor data access requests made through authorized agents. Implementing this control helps organizations meet their legal obligations, avoid potential legal liabilities, and maintain a high standard of data privacy and security.

Furthermore, having a well-defined process for handling authorized agents’ requests can enhance the organization’s reputation and build trust with customers and stakeholders. It demonstrates the organization’s commitment to protecting personal information and respecting individual rights, which can lead to improved customer satisfaction and loyalty.

In summary, the ‘Authorized Agents’ control is crucial for validating and managing data access requests made by individuals or entities acting on behalf of data subjects. It ensures compliance with data protection regulations, protects individuals’ privacy rights, and reinforces the organization’s commitment to data privacy and security.


Available tools in the marketplace

  • N/A – No tools recommendation for this control

Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

  • N/A – No available template for this control

Control implementation

Here are some guidelines to implement a program for setting and managing Authorized Agents:

  • Regulatory Understanding: Begin by thoroughly understanding the relevant data protection and privacy regulations applicable to your organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). These regulations may outline specific requirements for handling authorized agent requests.
  • Policy Development: Develop a clear and comprehensive policy that outlines the procedures and guidelines for handling authorized agent requests. This policy should specify the information required from the authorized agent, the authentication process, and the response timeframe.
  • Data Access Request Process Integration: Integrate the “Authorized Agents” process into your existing data access request management system or privacy management software. This may involve customizing the system to accommodate authorized agent requests and ensure they are handled separately.
  • Authentication Mechanism: Implement a robust authentication mechanism to verify the identity of authorized agents. This could involve using multi-factor authentication or other secure methods to prevent unauthorized access to personal data.
  • Validation of Authorization: Establish a process for validating the authorization of the agent to act on behalf of the data subject. This may include requesting additional documentation or confirmation of the agent’s authority.
  • Record-Keeping and Audit Trails: Maintain detailed records of all authorized agent requests and actions taken to fulfill them. This documentation should include the request date, agent identity, verification process, and response details.
  • Training and Awareness: Provide training to employees who handle authorized agent requests to ensure they understand the procedures and legal requirements. Raise awareness among staff about the importance of following the policy accurately.
  • Timely Response: Set clear timelines for responding to authorized agent requests. Ensure that responses are provided within the required timeframe specified by applicable regulations.
  • Third-Party Involvement: If third-party service providers handle authorized agent requests on behalf of your organization, ensure that they adhere to the same standards and guidelines outlined in your policy.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

  • Agent Authorization Letter Form
  • Authorized validation records (example of agent’s approval)

Evidence example

For the suggested action, an example is provided below:

  • Agent Authorization Letter Form

Screesnshot source



  • Authorized validation records (example of agent’s approval)

It will be the completed form.


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