If customer personal data reaches a hosted model provider on your behalf, that provider usually belongs on your subprocessor list, and you should answer the questionnaire that way. This is a general explainer, not legal advice, so confirm the classification with your counsel and your contracts.
Definitions
A subprocessor is a third party that processes customer data on your behalf in the course of delivering your service. A model provider is a company that hosts a model your product or tooling sends data to. When the second receives personal data from the first for your service, the two definitions meet.
Reviewers ask because their own contracts with you usually promise notice when subprocessors change.
When the provider is in scope
| Situation | Likely treatment |
|---|---|
| Customer text is sent to a hosted model to deliver a feature | List as subprocessor |
| Only your own non customer data is sent | Probably not, but describe it |
| Model runs inside your own environment | No external provider to list |
| Developers paste customer data into an assistant | Treat as a data handling incident risk, and fix the policy |
The last row matters. Even if your product never calls a model, internal tooling can create the same exposure.
What to check in the provider terms
- Is customer content used to train models, and can you opt out?
- How long is it retained, and is there a zero retention option?
- Where is it processed?
- Who can access it at the provider, and under what conditions?
- How do they notify you of incidents and changes?
- Is there a data processing agreement that covers your use?
Write down the answers with the date you read the terms. Provider terms change, so the date is part of the evidence.
Answer templates
Short: "Yes. Our summarisation feature sends document text to a hosted model provider, listed on our subprocessor page. The agreement excludes training use and sets a retention limit. We give customers notice of changes."
If you are unsure: "We are completing our review of the provider terms for feature X and will confirm by a date." Do not guess, because the answer may be quoted back to you later.
Keep the list alive
Subprocessor lists age quickly when teams add AI features. Add a step to your change review: any new service that receives customer data prompts a list update and customer notice where your contracts require it. Related: answering "do you train on our data" and data residency answers.
Evidence
The public subprocessor list, the provider data terms you reviewed with dates, and your change review checklist. Safeguard's SBOM and dependency scanning and asset discovery can show which services and SDKs your code actually calls, and compliance and evidence automation keeps the records.
Quick check
Does a prompt count as customer data?
If the prompt contains customer content or personal data, yes. Treat prompts like any other data flow and classify what goes in.
Do open weight models avoid this question?
Only if you run them in your own environment. Using a hosted service for an open model still involves the host as a provider.
Last reviewed: 19 October 2026.
