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Use one provider-specific control and evidence matrix, not a certificate checklist. Define the service boundary and data flows, identify UK GDPR roles and processing locations, map cardholder-data and cardholder-data-environment (CDE) impact, connect the service to important business services, and document the exit route. For every control, assign ownership to you, the provider or both; obtain evidence; test the control when appropriate; and record residual risk, an accountable owner, a review date and remediation actions. A certification or attestation covers only its stated scope, period and system components—it does not prove that your configuration or use is compliant.
What verification should produce
Your approval file should let a reviewer answer five questions without relying on marketing material:
- What exactly are we buying, including accounts, regions, interfaces, support access, sub-processors and fourth parties?
- Which legal, security, payment and resilience controls apply to this service?
- Who operates each control, and what evidence demonstrates that it works?
- What risks remain in our configuration, processes or contract?
- Could we continue the important service and retrieve our data if the provider failed or had to be replaced?
Keep the matrix tied to a named service and version. A provider-wide certification is useful only after you confirm that the purchased service, region, interfaces and relevant support processes are included.
Set the service boundary before reviewing evidence
Start with a current architecture and data-flow diagram. Include production and non-production accounts, administrative paths, customer-support access, APIs, backups, logs, encryption-key services, monitoring tools and disaster-recovery environments. Record where data is stored, replicated, viewed and technically accessible, including locations used by support personnel and subcontractors.
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Classify the information in each flow. At minimum, mark personal data, special-category data, payment-card data, sensitive authentication data, credentials, logs and business-critical records. Identify whether the provider can access the CDE or influence a security control even when it does not store card data itself.
List every sub-processor and material fourth party, the service each supplies, its location and the notice or approval process for changes. Record dependencies such as identity, networking, DNS, telecommunications, facilities and managed security services. For a regulated firm, link each dependency to the important business service it supports and its impact tolerance.
Build the control and evidence matrix
Use one row per requirement or testable control. The following columns are a practical minimum:
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| Matrix field | What to record |
|---|---|
| Requirement and source | UK GDPR Article 28 or 32, a PCI DSS v4.0.1 requirement, PRA SS2/21 expectation, contractual clause or internal policy. |
| Service and boundary | Product edition, region, accounts, interfaces, support channels, environments and excluded components. |
| Data or business impact | Personal-data categories, CDE connection, important-business-service dependency, impact tolerance and criticality. |
| Owner | Customer, provider or shared. Name the accountable internal owner even when operation is outsourced. |
| Evidence requested | Contract, data-flow schedule, audit report, attestation, test result, configuration export, policy or interview record. |
| Validation method | Document review, sampling, technical test, walkthrough, independent assessment or management confirmation. |
| Scope and validity | Covered services and locations, assessment period, report date, exclusions, exceptions and assessor details. |
| Finding and residual risk | Gap, likelihood and impact, compensating measure, remediation date and acceptance decision. |
| Review trigger | Scheduled date plus events such as a material change, incident, new sub-processor, region change or control failure. |
| Exit dependency | Data format, retrieval time, migration method, assistance, deletion proof and replacement option. |
Attach the source document or a stable reference for every evidence item. Mark evidence that is descriptive rather than independently tested, and note assumptions about your own configuration.
Verify UK GDPR requirements
The ICO expects a controller to use processors that provide sufficient guarantees. Your contract must require the processor to apply appropriate Article 32 measures, assist with compliance and permit audits. Use the ICO’s controller–processor contract guidance and data-security guide as the control baseline.
Confirm roles, purposes and instructions
- State whether you are controller, joint controller or processor and whether the cloud company is your processor or a separate controller for any processing.
- Describe processing purposes, data categories, data-subject groups, duration and documented instructions. Prohibit use for unrelated purposes unless a lawful role and instruction exist.
- Define confidentiality duties for personnel and restrict access to people who need it.
Control sub-processors and international access
Require prior specific or general authorisation for sub-processors, advance notice of proposed changes and a practical objection process. Keep a current register showing each sub-processor’s function and location. Include access from another country even when the primary storage region is in the United Kingdom or European Economic Area.
For restricted international transfers, identify the applicable transfer mechanism, complete a transfer-risk assessment where required, and document where data and support access occur. The location schedule should cover replicas, backups, telemetry and remote administration, not just the main database.
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Test Article 32 security and resilience
Assess measures proportionate to the risk, including:
- Encryption in transit and at rest, or pseudonymisation where appropriate, with documented key ownership and recovery.
- Confidentiality, integrity, availability and resilience of processing systems and services.
- Identity and access management, privileged-access controls, segregation, logging and monitoring.
- Vulnerability management, secure change processes, incident handling and regular security testing.
- Backup, restoration and continuity arrangements that can return systems to an effective state after an adverse event.
The ICO treats processors as subject to the security principle and explains that resilience includes continuing under adverse conditions and restoring systems to an effective state. Sample evidence rather than accepting a policy alone: an access-review sample, privileged-session record, recent penetration-test summary, backup-restore result and incident exercise report. Your test must also cover customer-managed settings such as keys, network rules, retention and administrator accounts.
Check assistance and end-of-contract obligations
The agreement should require timely assistance with data-subject access, rectification, erasure, restriction, portability and objection requests; personal-data breach notification; data-protection-impact assessments; and consultations with the regulator. Set notification contents, escalation contacts and deadlines so the processor can support your legal reporting window.
Specify return or deletion at termination, the format and timing of exports, treatment of legally required retention, deletion of replicas and backups, and evidence of completion. Reserve audit and inspection rights that are usable in practice, including access to relevant records and facilities or an equivalent independent assessment where justified.
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PCI DSS evidence can inform a security review, but the ICO states that PCI DSS compliance is not necessarily equivalent to UK GDPR security compliance. Do not substitute a payment assessment for the privacy contract, transfer analysis or data-subject assistance controls. See the ICO’s printable data-security guide PDF for the same security-principle detail.
Verify PCI DSS scope and validation
Decide whether the provider is in scope
PCI DSS applies to entities that store, process or transmit cardholder data or sensitive authentication data, and to entities that could affect the security of the CDE. A cloud provider can therefore be in scope when it can access the CDE, supplies a control on your behalf or facilitates payment-data flows, even if it does not directly retain card numbers. Use the PCI Security Standards Council’s PCI DSS overview and its cloud-scope FAQ while drawing the boundary.
Document every connection between the service and the CDE: virtual networks, identity services, management planes, logging, backups, support tools, APIs and hosted payment components. Record whether the provider’s systems are in the CDE, connected-to systems or an external service that can influence a security control.
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Request current, service-specific evidence
Ask for the provider’s current PCI DSS v4.0.1 Attestation of Compliance (AOC), Report on Compliance (ROC) or another form accepted by your acquirer or payment brand. Require the exact services and system components covered, assessment dates, exceptions, compensating or customised approaches, assessor identity and the responsibility matrix.
PCI DSS v4.0.1 was published on 11 June 2024. It added and deleted no requirements, while PCI DSS v4.0 retired on 31 December 2024; therefore, a v4.0 document is not the current baseline for a new review. Confirm the lifecycle details in the Council’s v4.0.1 publication notice.
Put shared responsibility in writing
Responsibility varies with the purpose of the service, the outsourced scope, validated components and whether the model is infrastructure, platform or software as a service. The Council’s cloud guidelines warn that outsourcing a control does not outsource your overall responsibility.
Create a component-by-component schedule covering physical facilities, hypervisor or platform, operating system, network controls, encryption, key management, vulnerability scanning, logging, access reviews, incident response, backups and application configuration. For each item, state who performs it, who supplies evidence and who checks completion. Include customer-side controls that remain yours even when the provider supplies the underlying technology.
Apply Requirement 12.8 and confirm reporting
Perform due diligence before appointment, maintain a written agreement, identify which requirements each party meets and monitor the provider’s PCI compliance status at least annually. Keep dated evidence of that review and of follow-up on exceptions. The Council describes these expectations in its Requirement 12.8 FAQ.
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Verify PRA outsourcing and operational resilience
For a PRA-regulated bank or insurer, use SS2/21, updated in March 2026, as the primary interpretation source. The statement contains cloud-specific conditions for safe and resilient deployment. Treat outsourcing as a board-level risk decision, not a procurement formality.
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Inventory services and map important business services
Maintain an inventory of outsourced and other third-party services. For each cloud service, map the people, processes, technology, facilities and information needed to deliver every affected important business service. Record the impact tolerance, the dependency’s position in the end-to-end chain and failure scenarios such as regional outage, identity-provider loss, corrupted backup or provider insolvency.
Use the FCA’s outsourcing and operational-resilience guidance as a companion: firms should understand and map dependencies, including third parties, and assess related risks and controls. FCA FG16/5 addresses cloud and other third-party IT outsourcing.
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- Board and senior management accountability for the outsourcing decision, risk appetite, oversight and remediation.
- A documented risk assessment covering security, availability, data, legal compliance, substitutability, financial stability and concentration.
- Due diligence on the provider’s capability, control environment, financial position, locations, subcontractors and history of incidents.
- Controls for concentration risk, including common providers, shared regions, shared technologies and material sub-outsourcing.
Negotiate supervisory access and incident clauses
Contracts should provide the firm, its auditors and the PRA with appropriate access to information, records, systems and premises, subject to practical arrangements that do not defeat the right. Include cooperation with supervisory requests, audit and inspection, retention of records, security requirements, data-location and access transparency, and notice of material changes.
Define incident-notification triggers, contacts, information to be supplied, update frequency and cooperation for containment, investigation and regulatory reporting. Require notification of material sub-outsourcing, location changes, control failures and events that could affect an important business service.
Prove continuity, recovery and exit
Obtain business-continuity and disaster-recovery designs, recovery objectives, dependency assumptions and results from recent tests. Challenge whether tests exercised the actual regions, accounts, keys, interfaces and staff needed by your service, rather than a generic provider scenario. Record defects, owners and retest dates.
Maintain a documented, tested exit or substitution plan. It should identify an alternative provider or internal route, data and configuration export formats, transfer bandwidth, licensing, people, tooling, contractual assistance, parallel running, validation and secure deletion. Test a representative extraction and restoration where feasible, and measure whether the result fits the important business service’s impact tolerance.
Assemble and validate the evidence pack
- Define scope. Freeze the architecture, accounts, regions, support paths, data classes, CDE links, sub-processors and fourth parties for the assessment period.
- Collect provider evidence. Obtain the Article 28 data-processing agreement, data-flow and location schedule, sub-processor register, security and penetration-test summaries, incident and breach process, resilience and recovery-test results, deletion or return evidence, PCI AOC/ROC, responsibility matrix, supervisory-access clauses and exit documentation.
- Check scope and currency. Match every report to the purchased service, edition, region, interfaces and assessment period. Note exclusions, customer-side controls, exceptions, compensating controls, customised approaches and assessor details.
- Test the customer boundary. Sample access reviews and logs; inspect key-management and network settings; perform or witness a backup restoration; walk through incident notification; verify sub-processor-change alerts; and execute a limited data-export and import test.
- Record decisions. For each gap, assign severity, accountable owner, due date, interim measure and risk-acceptance authority. Do not approve an unresolved high-impact dependency merely because a report is clean.
- Set monitoring. Schedule at least annual PCI-status monitoring, privacy and security reviews, PRA governance reviews, and event-driven reassessment after incidents, material changes, new regions, new sub-processors or changes to the CDE or important business service.
Use decision gates rather than a single pass/fail certificate
| Gate | Approve only when | Typical stop condition |
|---|---|---|
| Privacy and data transfer | Roles, instructions, locations, sub-processors, security measures, assistance, audit and deletion terms are enforceable. | Unknown support access, unapproved sub-processors or no workable transfer mechanism. |
| Payment security | The CDE boundary is documented, current v4.0.1 evidence covers the service, and customer/provider responsibilities are tested. | Evidence covers a different product or region, or no party owns a required control. |
| Resilience and supervision | Important-business-service mapping, impact tolerance, continuity tests, supervisory access and exit plan are complete. | Recovery depends on an untested assumption, concentration is unassessed or exit is theoretical. |
| Residual-risk approval | Open findings have owners, dates, interim controls and approval at the right level. | Material risk is accepted informally or without a remediation path. |
When several providers meet the minimum gates, compare them on four dimensions: UK GDPR role, geography, transfer and sub-processor controls; security, resilience, auditability and evidence quality; PCI scope, v4.0.1 validation and shared responsibilities; and PRA governance, concentration, incident, continuity and exit capability. The least expensive or most certified option is not automatically the lowest-risk option because the boundaries and customer obligations differ.
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Common verification failures and corrective actions
“The provider is certified, so our use is compliant”
Replace the conclusion with a scope comparison. Identify the certified services, locations, period, exclusions and controls assigned to the customer, then test your configuration.
“The cloud company does not store card data, so PCI does not apply”
Trace CDE access and influence. A provider can remain in scope through administrative access, a security control it operates or payment-data flows it facilitates.
“The contract says the provider is responsible for security”
Convert the clause into a control schedule naming components, evidence, testing, notification duties and customer settings. Retain an internal owner for every shared or customer control.
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“A recovery-time objective appears in the brochure”
Require test results for the purchased region and dependency chain. Verify that restoration includes identity, keys, networking, data integrity, interfaces and people, and compare the measured result with the impact tolerance.
“Exit will be handled if needed”
Make exit operational now: define export formats, assistance, costs, retention and deletion, identify a substitute, and test a representative migration before the service becomes critical.
What to retain for audit and board oversight
Keep the approved matrix, architecture and data-flow versions, contracts and amendments, evidence index, validation notes, test scripts and results, risk acceptances, remediation tracking, annual PCI review, sub-processor notices, incident records, resilience exercises and exit-test results. Link each artefact to the service owner and review date. A dated, reproducible record demonstrates not only that evidence was requested, but that your organisation understood its boundary, challenged assumptions and acted on remaining risk.
Quick Recap
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