Free tool

Vendor security and GDPR questionnaire builder for universities

Describe the tool you are buying in seven short questions and get a vendor questionnaire that asks only what matters for it. Every question comes with the reason, the legal or standard reference, and the evidence to request. Copy it, download it as CSV or Markdown, or print it.

Published 9 October 2026 · Sources checked 9 October 2026

Also available in: Svenska · Nederlands · Norsk · Suomi · Dansk · Français · Español · Português

The short version

For example "AI transcription of research interviews" or "online exam platform". It only appears in the questionnaire header.

Tick all that apply. User accounts, logs and SSO attributes are personal data too.

Member states may apply NIS2 to education institutions (Directive (EU) 2022/2555, Art. 2(5)(b)). See our NIS2 guide for universities.

Runs entirely in your browser. Nothing you type or tick is stored or sent anywhere.

Contents

  1. What is a vendor security questionnaire?
  2. Why tailor the questionnaire?
  3. How the builder chooses questions
  4. Is there a HECVAT alternative for Europe?
  5. How do you evaluate the answers?
  6. Red flags in vendor answers
  7. How universities run vendor assessments
  8. Sources
  9. About this page

What is a vendor security questionnaire?

A vendor security questionnaire is a structured set of questions a university sends to a supplier before buying or renewing a service. It asks how the supplier protects data, which laws it meets and which documents prove it. Used well, it is an index to evidence: each answer points to a contract clause, certificate, report or list you can check.

In a European university the questionnaire serves several people at once. The data protection officer needs the processor terms, subprocessors and transfers under the GDPR. IT security needs certificates, encryption, access control and incident handling. Procurement needs contract, liability and exit terms, and increasingly someone needs to check AI features against the EU AI Act and accessibility against EN 301 549. Our vendor assessment guide for universities describes the whole process; the questionnaire is one step in it.

Why tailor the questionnaire?

Because long, generic questionnaires produce poor answers. Vendors that sell to many universities receive hundreds of questionnaires a year. When a 300-line spreadsheet arrives for a simple tool with no personal data, the answers are often copied from a previous response, and the questions that matter are lost among the ones that do not.

Tailoring helps both sides:

Risk-based scoping is also how sector questionnaires work now. EDUCAUSE says HECVAT 4 starts with scoping questions that decide which questions apply (see our HECVAT guide for European universities). Several universities scale their process by value or data, as the examples below show.

How the builder chooses questions

The builder gives the tool a score from your intake answers. Personal data, special category data, data about minors, generative AI, unknown or non-EEA hosting, broad integrations, NIS2 scope and a high contract value each add to it. The score sets a tier, and every question in the bank has a minimum tier and, where relevant, a trigger.

TierTypical toolWhat it includes
LightA low-value tool with little or no personal data, hosted in the EEA, no AICore contract, security and accessibility questions, plus the core GDPR items if there is any personal data
StandardA service with staff or student data, SSO or an LMS integration, or AI featuresAdds the remaining Article 28(3) points, access control, logging, vulnerability management, incident response and exit
FullSpecial category data, minors, generative AI on student data, unknown hosting, or a high-value tenderAdds transfer impact assessments, secure development, staff security, AI governance and supply chain questions

Triggers work independently of the tier. If you tick LTI, you get the LTI 1.3 and roster-data questions. If the tool uses generative AI, you get the training, model provider, prompt retention and Article 50 transparency questions. If hosting is outside the EEA or not known, the transfer questions move up to the light tier. Special category data and data about minors always produce a full questionnaire.

The result is a starting point. Delete questions that do not fit, and add your own institutional requirements, such as national security classification rules or library licence terms.

Is there a HECVAT alternative for Europe?

The HECVAT is still useful in Europe, but it does not replace the EU-specific questions. The HECVAT, maintained by EDUCAUSE with Internet2 and REN-ISAC, is a broad security, privacy and accessibility questionnaire that many vendors to higher education have already completed. European law needs specific documents: an Article 28 processor contract, a transfer tool for each non-EEA recipient, an AI Act classification and an EN 301 549 conformance report.

TopicHECVAT 4This builder
ScopeOne file with scoping questions; a shorter "lite" view of critical questionsTailored subset of a 90-question bank, chosen from seven intake answers
Legal anchorWritten for higher education generally, with US originsGDPR, EU AI Act, NIS2, Data Act, Web Accessibility Directive, Cyber Resilience Act
EvidenceAnswers in a spreadsheet, scored by the institutionEach question names the evidence to request
LicenceFree for colleges, universities and their vendors; owned by EDUCAUSEFree; written from scratch, not derived from the HECVAT

Validemic's analysis
If a vendor sends a recent HECVAT 4, accept it for the general security questions and send only the EU-specific domains from this builder: GDPR and the DPA, subprocessors, transfers, AI and accessibility. That avoids asking the vendor the same thing twice. For a Word version with 77 questions in 11 sections, see the European vendor questionnaire on our HECVAT page.

Reviewing a vendor right now? Validemic checks the vendor's documents against GDPR and the EU AI Act and cites every finding. Try the demo workspace

How do you evaluate the answers?

Evaluate the evidence, not the answer text. A questionnaire answer is the vendor's statement; the decision should rest on the documents it points to. Read each answer next to its evidence, note gaps, and send one round of follow-up questions before you decide.

  1. Check that the answers match the plan you are buying. Privacy terms, AI training defaults and data location often differ between free, education and enterprise plans.
  2. Read the DPA against Article 28(3). Each of points (a) to (h) must be in the contract, not only in the questionnaire. Our DPA checker maps a draft agreement point by point.
  3. Check the subprocessor list and data flows. The EDPB says controllers should have the identity of all processors and subprocessors "readily available at all times" (Opinion 22/2024). Compare the list with the data locations and remote access answers, then use the transfer mechanism tool for each non-EEA recipient.
  4. Check certificates for scope and date. An ISO/IEC 27001 certificate or SOC 2 report matters only if it covers the product and hosting you are buying, and is current.
  5. Classify AI features. Use the AI Act checker for education for any feature that grades, admits, places or proctors students.
  6. Decide whether a DPIA is needed. Run the DPIA screening with what you have learned.
  7. Record conditions. Approve with conditions where needed, for example "SSO only" or "AI features switched off", and set a review date.

Red flags in vendor answers

Validemic's analysis
None of these answers is automatically disqualifying. Each one needs a follow-up question before approval.

Answer patternWhy it mattersFollow-up
"We are fully GDPR compliant" with no documentCompliance depends on contract, configuration and useAsk for the DPA clause and the role statement
Data stored in the EU, access locations not statedThe EDPB treats remote access from a third country as a transferAsk where support and engineering staff access data from
Subprocessor list "available on request"You need the identities now, and notice of changes laterAsk for the current list and the change notification method
Customer data "may be used to improve our services"This can include AI training, and makes the vendor a controller for that useAsk for a contractual commitment for your plan
"We notify breaches within 72 hours"72 hours is the controller's deadline; the processor must notify without undue delayAsk for a shorter commitment, such as 24 or 48 hours
Certificate without scope, or an expired SOC 2 periodIt may not cover the product, the hosting or the presentAsk for the scope statement and the latest report
Accessibility: "WCAG compliant" with no reportA claim without a test method and date cannot be checkedAsk for a conformance report against EN 301 549 V3.2.1
Browser extension asks to read all websitesIt can see email, the LMS and student recordsAsk whether permissions can be limited by admin policy

Unapproved tools often skip this review entirely. Our guide to shadow IT and AI tools in universities covers how to bring them into the process.

How universities run vendor assessments

Published university procedures show the same pattern: assessment is triggered by data or system access, its depth depends on risk or value, and it starts well before the contract.

The builder follows the same logic: the intake sets the depth, and the output separates what to ask from what to verify.

Sources

All sources retrieved 9 October 2026. EU legal texts were read in the Official Journal versions from the Publications Office and are linked on EUR-Lex.

  1. Regulation (EU) 2016/679 (GDPR), in particular Articles 3, 5, 8, 9, 22, 25, 27, 28, 30, 32 to 36, 44 to 49 and 89: eur-lex.europa.eu/eli/reg/2016/679/oj/eng
  2. Regulation (EU) 2024/1689 (AI Act), Articles 3, 4, 5, 6, 13 to 15, 25 to 27, 50 and 53 and Annex III: eur-lex.europa.eu/eli/reg/2024/1689/oj/eng
  3. Regulation (EU) 2026/1744 (Digital Omnibus on AI), amending Article 4, Article 50 transition and Article 113 dates: eur-lex.europa.eu/eli/reg/2026/1744/oj/eng
  4. Directive (EU) 2022/2555 (NIS2), Articles 2(5), 21 and 23 and Annexes I and II: eur-lex.europa.eu/eli/dir/2022/2555/oj/eng
  5. Regulation (EU) 2023/2854 (Data Act), Articles 25 and 29: eur-lex.europa.eu/eli/reg/2023/2854/oj/eng
  6. Regulation (EU) 2024/2847 (Cyber Resilience Act), Articles 14 and 71: eur-lex.europa.eu/eli/reg/2024/2847/oj/eng
  7. Directive (EU) 2016/2102 (Web Accessibility Directive), Article 7: eur-lex.europa.eu/eli/dir/2016/2102/oj/eng
  8. Commission Implementing Decision (EU) 2021/1339 (reference of EN 301 549 V3.2.1): eur-lex.europa.eu/eli/dec_impl/2021/1339/oj/eng
  9. Directive 2014/24/EU (public procurement), Articles 4, 42(1) and 58(4): eur-lex.europa.eu/eli/dir/2014/24/oj/eng
  10. Commission Implementing Decision (EU) 2018/1523 (model accessibility statement): eur-lex.europa.eu/eli/dec_impl/2018/1523/oj/eng
  11. Directive 2002/58/EC (ePrivacy Directive), Article 5(3) as replaced by Directive 2009/136/EC: eur-lex.europa.eu/eli/dir/2009/136/oj/eng
  12. Commission Implementing Decision (EU) 2021/914 (standard contractual clauses), Clauses 14 and 15: eur-lex.europa.eu/eli/dec_impl/2021/914/oj/eng
  13. Commission Implementing Decision (EU) 2023/1795 (EU-US Data Privacy Framework): eur-lex.europa.eu/eli/dec_impl/2023/1795/oj/eng
  14. EDPB, Opinion 22/2024 on certain obligations following from the reliance on processor(s) and sub-processor(s), adopted 9 October 2024: edpb.europa.eu, Opinion 22/2024
  15. EDPB, Guidelines 07/2020 on the concepts of controller and processor in the GDPR: edpb.europa.eu, Guidelines 07/2020
  16. EDPB, Recommendations 01/2020 on supplementary measures for transfers, version 2.0, paragraph 13 (remote access is a transfer): edpb.europa.eu, Recommendations 01/2020
  17. ENISA, Good Practices for Supply Chain Cybersecurity (13 June 2023): enisa.europa.eu
  18. EDUCAUSE, Higher Education Community Vendor Assessment Toolkit (HECVAT): educause.edu (details as summarised in our HECVAT guide, checked 7 October 2026)
  19. ISO/IEC 27001:2022, Information security management systems: iso.org/standard/27001; ISO/IEC 42001:2023, AI management systems: iso.org/standard/42001
  20. ETSI EN 301 549 V3.2.1 (2021-03), Accessibility requirements for ICT products and services: etsi.org (PDF)
  21. 1EdTech, Learning Tools Interoperability (LTI 1.3 and LTI Advantage): 1edtech.org/standards/lti
  22. University of Aberdeen, "How to undertake a supplier assessment" (21 October 2020): abdn.ac.uk
  23. University of Edinburgh, Information Security, "Using cloud services": infosec.ed.ac.uk
  24. Luleå University of Technology, "Guidelines for information security in procurement and purchasing" (LTU-2486-2021, 4 December 2023): ltu.se (PDF)
  25. Montclair State University, Information Security, "Vendor Assessment (HECVAT)": inside.montclair.edu

About this page

We wrote the question bank from the legal texts and standards listed above, read on 9 October 2026, and from published university procedures. The questions are our own and are not taken from the HECVAT or any other licensed questionnaire. References point to the provision a question relies on; where a provision applies only in some cases (for example high-risk AI systems, or data processing services under the Data Act), the question says so. The pending GDPR changes in the Commission's Digital Omnibus proposal are not law and are not reflected. This tool is not legal advice, and the university remains responsible for its assessment. If you find an error or a reference that has changed, please contact us and we will correct it.

Frequently asked questions

What is a vendor security questionnaire?

It is a structured list of questions a buyer sends to a supplier before buying, to learn how the supplier protects data and meets legal duties. Good questionnaires ask for evidence such as certificates, contracts and subprocessor lists, not only for yes or no answers.

How many questions should a vendor questionnaire have?

As many as the risk needs and no more. A simple tool with little personal data may need about 20 questions, a typical service with student data or AI features 35 to 50, and a high-risk platform with special category data or minors 70 or more. Asking everything every time slows reviews and lowers answer quality.

Is there a HECVAT alternative for European universities?

The HECVAT is a broad security and privacy questionnaire from EDUCAUSE and remains useful evidence. European universities usually add questions on GDPR Article 28 processor terms, international transfers under Chapter V, the EU AI Act and EN 301 549 accessibility, because those laws need specific documents rather than general answers.

What should a GDPR vendor questionnaire include?

At minimum: the vendor's role for each purpose, a data processing agreement covering Article 28(3)(a) to (h), the subprocessor list and change process, data locations and remote access, the transfer tool for each non-EEA recipient, security measures, breach notification timing, and deletion or return of data at the end.

Do AI tools need extra vendor questions?

Yes. Ask whether your inputs and outputs are used to train models, which model providers process the data and where, how long prompts are kept, whether any feature is a high-risk use under Annex III point 3 of the AI Act, and how the vendor meets the Article 50 transparency duties.

Is the questionnaire builder free and private?

Yes. The tool runs entirely in your browser. Nothing you type or tick is stored or sent to Validemic or anyone else, and you can download the result as CSV or Markdown and edit it freely.