Knowing who else handles your data: sub-processors in consent
The suppliers who handle shared data are rarely part of the consent. An Essence consent can fix the exact sub-processor list a person was shown, and the rule for when it changes, into the receipt.
Say you share three fields from your vault with a lettings app: your name, your employer and your monthly income. You have read who the app is and why it wants them. What you probably have not seen is that the app uses a hosting company, an email service and a referencing agency, and each of them may handle those fields on its behalf.
In data protection law these are sub-processors, and Article 28 of the GDPR expects them to be named and controlled. When people see the list at all, it is usually a web page that can change next week. If a dispute comes up two years later, nobody can say which version was on screen when consent was given.
Since our October release, an Essence consent can answer that question.
A register for each app
It starts with a register. Since our August release, Essence has held a sub-processor register for each organisation's apps. Each entry records the sub-processor's name, its role, its jurisdiction, the lawful basis for engaging it, the purpose and the date it was engaged.
Each version of an app's list is published with a version number, a date and a digest: a SHA-256 fingerprint of the list's exact content. Change one character in one entry and the fingerprint changes. When an organisation changes its list, a notice goes to each person who holds an active consent with that app.
The list, fixed into the consent
When a person consents, the consent record can hold five things about the list they were shown: which app's list it was, its version, the date that version was published, its fingerprint, and the rule that applies if the list changes.
These are bound into the consent receipt when the consent is created and never rewritten. If the organisation adds a supplier next year, the receipt still says what the person was shown, at which version and on which terms. The record holds governance information only. None of it is the person's own data.
When the list changes
Lists do change, and Essence supports two rules for what happens next. Each consent takes its rule from the person's account default or from a setting for that app.
Notify and object. The person is told about the change and can object. Sharing continues unless they do.
Ask for consent again. Sharing with that app pauses when the change is announced and resumes only if the person approves again. If they do not answer, it stays paused.
Which rule fits depends on the data. For a newsletter, a notice is probably enough. For health or financial fields, many people would rather be asked again.
Evidence that cannot be half recorded
A disclosure record is either complete or refused. The fingerprint is calculated over a fixed layout that includes the app, the version and the date, so a fingerprint stored without them is a number nobody can recompute. A version stored without the chosen rule says what was shown but not what was agreed. Either would look like evidence and prove nothing, so the consent service does not store it.
The same care applies on the person's screen. Their app does not make up the fingerprint. The register publishes it, and the app recalculates it over the entries it actually displayed. If the two differ, the list on screen is not the list the register published, and the app has to say so rather than record a fingerprint for entries the person never read.
What this means for your organisation
For an organisation that receives data through Essence, the sub-processor list can stop being a page on a website and become part of the consent itself, captured at the moment the person agreed. An auditor's question changes from "what does your website say today?" to "show me the fingerprint in this receipt and the register version it matches", and that question has a checkable answer. If your organisation shares personal data with suppliers and wants consent to carry that list, we would be glad to show you how the register and the receipt work together.
Published 29 October 2026