How do I work out who I owe notice to when a sub-processor changes?

From your own agreements, one row per agreement. Note the customer, what triggers the notice, the clause quoted and your period. Then subtract your period from the vendor's window.

How long do AI vendors give you to object to a sub-processor?

Every one of the 81 clauses we quote states 30 days or fewer. The median is 15 days, and 25 give 10 calendar days or fewer, counting a business day as 7/5 of a day. The window runs from the vendor's notice, not when you find out.

What if I promised my customer 30 days' notice?

Then 49 of those 81 vendors leave you late before you begin, 32 leave you exactly none, and 0 leave you any slack.

Should I record a summary of the clause or quote it?

Quote it. The words are the obligation, and a summary is where you and your own lawyers will end up disagreeing.

Does it matter whether the period is in business days?

Yes. Ten business days and ten days are four days apart in an ordinary two weeks, and more around a public holiday. Record which, in its own column.

Free worksheet · Customer notice

How many days do you really have to tell your customers?

Your contracts promise customers notice when your vendors change things. Your vendors’ own windows are often shorter.

This worksheet does the subtraction, one row per agreement.

Days you have = the vendor’s window − the notice you promised

Here’s how much time your vendors give you.

days: the median window across 81 published vendor clauses.

of them give 10 calendar days or fewer.

of 81 leave you late before you start, if you promised 30 days.

If you promised	Vendors leaving you late	Leaving exactly none	Leaving a day or more
30 days	49 of 81	32 of 81	0 of 81
14 days	25 of 81	8 of 81	48 of 81
10 days	8 of 81	17 of 81	56 of 81
5 days	0 of 81	5 of 81	76 of 81

The promise column is our example, not a measurement. We hold no customer agreements, and never will. The vendor side is counted from the published clauses.

Their clock starts first.

The vendor’s window runs from their notice, not from when you find out. If the notice is an edit to a web page, part of it is gone before you read the page.

A cartoon. A records clerk on a stepladder peers through a magnifying glass at the smallest of five hourglasses on a shelf. Their tags read “5 days”, “10 days”, “30 days” and “60 days”; the largest has a blank tag. — Some windows are shorter than others.

Six columns.

Fill the first four once per agreement. Recompute the last two whenever a vendor changes its window.

01
Counterparty
Who you owe the notice to. One row per agreement, not per customer. A master agreement with three orders under it is one row.
02
What triggers it
A new sub-processor, a security breach, or a change that matters. Three different clocks, each with its own period.
03
The clause, quoted
The words, not your summary of them. The words are the obligation.
04
Your period
The number, and whether it is business days. “Ten business days” and “ten days” are four days apart in an ordinary two weeks, and more around a public holiday.
05
The vendor's window
How long their agreement gives you to object, or how much notice it promises before a change. Either way it starts at their notice, not when you find out.
06
Days you actually have
Their window minus your period. This number decides whether you make the deadline, and it can be negative.

Filled in, it looks like this.

Three example clauses, read the way Xither reads an agreement you upload. The rows are what it found.

Counterparty	Trigger	Your period	The clause, quoted
Enterprise customer (MSA)	Notice of a new sub-processor	30 days	“Supplier shall notify Customer in writing at least thirty (30) days prior to appointing any new sub-processor that will process Customer Personal Data, and Customer may object on reasonable data protection grounds within that period.”
Enterprise customer (DPA)	Notice of a security breach	24 hours	“Supplier shall notify Customer without undue delay and in any event within twenty-four (24) hours of becoming aware of any personal data breach affecting Customer Personal Data.”
Public sector framework	Notice of a material change	10 business days	“The Supplier will inform the Authority no less than ten (10) business days before implementing any material change to the Services or to the manner in which Authority Data is processed.”

The clauses are written to sound like a negotiated enterprise agreement and are nobody’s actual contract.

Four habits that keep it right.

One row per agreement.
Not per customer. A master agreement with three orders under it is one obligation and three people to email.
Quote the clause.
Copy the words, not your summary. The words are the obligation.
Note business days.
Ten business days and ten days are four days apart in an ordinary two weeks, and more around a public holiday. Give it its own column.
Recompute when a vendor moves.
Their window is the one that changes. Redo the last column whenever it does.

Once you know who you owe, here’s the notice to send them.

Take the worksheet with you.

A Word file with the columns, the sum and a blank sheet, with vendor windows as they stand the day you open it.

Common questions.

How do I work out who I owe notice to when a sub-processor changes?: From your own agreements, one row per agreement. Note the customer, what triggers the notice, the clause quoted and your period. Then subtract your period from the vendor's window.
How long do AI vendors give you to object to a sub-processor?: Every one of the 81 clauses we quote states 30 days or fewer. The median is 15 days, and 25 give 10 calendar days or fewer, counting a business day as 7/5 of a day. The window runs from the vendor's notice, not when you find out.
What if I promised my customer 30 days' notice?: Then 49 of those 81 vendors leave you late before you begin, 32 leave you exactly none, and 0 leave you any slack.
Should I record a summary of the clause or quote it?: Quote it. The words are the obligation, and a summary is where you and your own lawyers will end up disagreeing.
Does it matter whether the period is in business days?: Yes. Ten business days and ten days are four days apart in an ordinary two weeks, and more around a public holiday. Record which, in its own column.

Tell your customers

More for this job.

See every resource

This isn’t legal advice, and the columns are a starting point, not a set anyone has approved for your situation. The vendor clauses are published agreements, read on the dates we hold. Your signed contract governs, and it may differ from the public version. Corrections are free to request.