Regulatory Alerts2021-03-08
Added · Updated
Software-as-a-Service as an Outsourcing Arrangement
The document establishes that Software-as-a-Service (SaaS) arrangements generally qualify as outsourcing if performed on a recurrent or ongoing basis and involve functions that could realistically be performed by the licence holder. Licence holders are required to assess whether their SaaS usage constitutes an outsourcing arrangement and determine if it involves a critical or important function. They must manage associated outsourcing risks, including data processing risks, business continuity, and migration strategies, while subjecting Third Party Providers to adequate due diligence.
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