External training providers may process participant data, login details, test results or completion records. First identify the provider’s role in the specific processing. If personal data are processed on the company’s behalf, Article 28 GDPR must be considered. This includes processing on documented instructions, confidentiality and suitable technical and organisational measures.
Check which information the provider actually collects and which certificate the company needs. An internal accountability record may need only a completion status. A full answer history or detailed usage log may create an additional purpose. The contract should also address how records are supplied, corrected, erased and returned or removed at the end of the service.
Responsibilities must remain clear where several providers are involved. The company should state who approves the content, who checks attendance and who initiates erasure. Provider certificates or standard reports can support the organisation’s evidence. They do not replace checking whether scope, target group and retention practice fit the actual processing.