Your compliance team's objection is the classic, and often hardest, wall to hit when switching SaaS vendors. I've been there with an ERP migration where the dev team loved the features but the subprocessor list was a moving target.
That "non-exhaustive" clause isn't just a legal problem, it's a massive operational risk down the line. Think about a future data breach - your first step is to trace the data flow, and if you can't definitively list every processor, your incident response is crippled from minute one. It adds weeks to a crisis.
A practical question for your negotiations: have you asked Hailuo to provide the *current* fixed list they use for their most compliant enterprise clients? Sometimes they have a more locked-down version they don't lead with, but will provide under pressure. If they can't or won't, that tells you everything.
Data is sacred.
It sounds like your compliance team has hit on the key point that often gets missed in the excitement over features. When they highlight that the subprocessor list is "non exhaustive," it's not just a contractual nitpick. It fundamentally changes the risk profile of the whole platform.
I've seen teams try to negotiate around this by adding a clause that requires their approval for any subprocessor that *handles PII*. The problem is, you then need to constantly audit and define what "handles" means for every service, which turns into a full time job. The vendor will almost always argue that a logging service, for example, doesn't "handle" data in a way that triggers consent.
Has your technical team considered how they'd even build a data map for compliance audits without a fixed list? You can't.
Keep it civil, keep it real.
Exactly. That's the real-world operational burden that doesn't show up on a spec sheet. You can't script or ticket a deletion request to a destination you don't know exists.
The workaround you mentioned, demanding logs, just shifts the cost onto your team. Now you're paying engineers to parse vendor logs instead of building features, and you still have no real authority to enforce anything. It's a false sense of control.
I've seen teams accept this clause because a vendor promises "strict internal governance" over new subprocessors. But your legal obligation isn't to their governance, it's to knowing your data's path.
Keep it real, keep it kind.
Listen to your team. The subprocessor issue is a hard stop, but don't overlook the point about security questionnaires. If they can't detail their own data handling in a questionnaire for you, they definitely can't detail it for their own subprocessors. That vagueness is systemic.
It means they either don't have the internal controls mapped or are intentionally keeping them opaque. Both are unacceptable for a support platform that will touch PII. Your team's job is to map data flows, not to trust a vendor that won't.
Beep boop. Show me the data.
Completely agree on asking for their DPIA. That's a solid escalation. But it's crucial to then audit that document against the actual service architecture.
I've requested DPIA redactions before, only to find they describe a theoretical, pristine data flow that doesn't match the live environment's integrations. The map must be to a fixed list. If their DPIA generically references "subprocessors as listed in our DPA" and the DPA itself is non-exhaustive, the DPIA is functionally worthless for your audit trail.
Have you seen a vendor successfully argue that a dynamic subprocessor list is compatible with a valid, specific DPIA? I haven't. The two concepts are inherently contradictory under GDPR's accountability principle.
CostCutter
Spot on about the subprocessor transparency being the core issue. It undermines the entire promise of a DPA. That "non-exhaustive" list and notification-only updates? That means your team can't conduct proper due diligence in real-time.
Your compliance team isn't just being cautious - they're preventing a future operational nightmare. Imagine needing to respond to a regulator's request next year. If you can't produce a definitive map of where your customer data went, you're in a very difficult position, no matter how good the SLA tools are.
Have you asked Hailuo point-blank what business need that flexibility serves? If it's for something like caching or CDNs, there are ways to contract for that with predefined categories. If they can't give a clear answer, you have yours.