I'm running up to the deadline to be compliant with Reg S-P. I've contacted Salesforce to get their statement assuring notification of breaches of their system that may expose our data. The regulation says they need to notify us within 72 hours. My "rep" says this requires a legal addendum to our contract. I find that hard to believe.
1) Has anyone been told the same?
2) Has anyone found a different method that meets compliance? (ex: SF Documentation they are compliant with GDPR)
Thanks,
Bob
Bob — yes, you're not alone. We've heard the same from others navigating this with large SaaS vendors. Salesforce routing it through a legal addendum is pretty consistent with how they've handled similar requests.
To your second question: beyond a formal addendum, other approaches that firms have used include a written questionnaire or attestation from the service provider acknowledging the 72-hour notification obligation, or documenting a risk-based vendor oversight decision if a contractual commitment isn't obtainable. The SEC gave some flexibility here — what matters is that your written policies reflect a reasonable effort to obtain that assurance and that you can demonstrate it during an exam.
On the preparedness side, it's worth getting clear now on exactly what NPI lives in your Salesforce org — things like account numbers, SSNs, income data, credit info, or transaction history. If a breach occurs, Reg S-P requires you to notify affected individuals within 30 days of becoming aware, and the notice needs to clearly describe what information was compromised, the potential risk of harm, and what steps individuals can take to protect themselves. Knowing your data footprint in advance makes that process significantly less painful.
For what it's worth, our team at LASER Credit Access works with financial institutions on Salesforce regularly and these compliance questions come up a lot. Happy to compare notes if it's helpful. Good luck on the deadline.