Do I need to sign a DPA with all the vendors?

Yes. According to the General Data Protection Regulation (GDPR), contractual clauses ensuring appropriate data protection safeguards can be used as a ground for data transfers from the EU to third countries. 

GDPR compliance requires data controllers to sign a data processing agreement with any parties that act as data processors on their behalf.

A DPA Is required if your vendor processes, stores, or accesses personal data on your behalf or you share personal data with the vendor for any reason such as cloud services, marketing tools, or payroll management. 

This includes model contract clauses – so-called standard contractual clauses (SCCs) – that have been “pre-approved” by the European Commission. 

Even if you are a Data Processor and the in-scope data is already outside the EU, you will likely still need Standard Contractual Clauses (SCCs) in place under GDPR if personal data is transferred from the EU to a non-EU country. Here’s why:

GDPR applies to EU data subjects’ personal data, regardless of where the data is processed or stored. If you’re processing or handling data from the EU, you must comply with GDPR rules.

SCCs are a mechanism to ensure compliance when transferring personal data outside the EU or EEA, particularly to countries that are not deemed to have adequate data protection laws by the European Commission.

Even if the data is already outside the EU, if you’re processing it on behalf of an EU-based data controller, you must ensure the data transfer meets GDPR requirements. This generally includes SCCs unless another lawful transfer mechanism is in place.

Your DPA should include how the vendor handles data, ensures compliance with GDPR requirements, implements data protection measures, handles breach notification processes, and other legal responsibilities.