
What to do when a vendor tells you they were breached
A breach notice from a supplier, software provider or service firm can land your organization with its own obligations. Here is how to work out what it means for you.
Reviewed by the ITRS security team · Last updated
Read the notice carefully
Vendor breach notices are often written by lawyers to say as little as possible. Read it for specifics: what systems were affected, when, what types of data, whether your organization's data is confirmed as involved or only 'potentially' involved, and what the vendor wants you to do. Note the date you received it; it starts your own clock for assessing the breach.
Check that the notice is genuine. Attackers sometimes send fake breach notices to get people to 'reset' credentials on a phishing page. Verify through the vendor's website or a known contact, not links in the notice.
Questions to send the vendor
- Is our data confirmed as accessed or taken, and which records or fields?
- What was the date range of unauthorized access?
- Were credentials, API keys, tokens or integration secrets for our account exposed?
- Was our data encrypted, and were the keys also exposed?
- Has the attacker's access been closed, and how was it confirmed?
- Are you notifying affected individuals directly, or do you expect us to?
- Have you reported to the Privacy Commissioner or other regulators?
- Who is our contact for updates, and when will we hear next?
- Will you share a summary of the forensic findings?
Rotate shared credentials and API keys
Assume that anything the vendor held that lets someone into your systems is burned until shown otherwise. That includes accounts your staff use on the vendor's platform, API keys and OAuth connections between your systems and theirs, service accounts or VPN access you gave the vendor, and any password reused anywhere else.
Review sign-in and API logs on your side for the breach window. If the vendor had remote access to your network, as many managed service and software providers do, treat this as a possible incident on your own network. The Canadian Centre for Cyber Security publishes guidance on supply chain and managed service provider risk that's worth reading in this situation.
Is your data involved? Your obligations
Under PIPEDA, the organization in control of personal information is responsible for it, including when it is transferred to a third party for processing. Schedule 1, Principle 4.1.3 says organizations must use contractual or other means to provide a comparable level of protection while information is being processed by a third party. In practice, when a processor is breached, the controlling organization may be the one that must assess real risk of significant harm, report to the OPC, notify individuals, and keep a breach record.
Your lawyer should decide who notifies whom. Sometimes the vendor notifies individuals on your behalf; sometimes you must. Either way, document your own assessment and keep it with your breach records for 24 months.
Watch for follow-on phishing
Stolen customer lists and invoice data fuel targeted phishing. For the next several months, expect emails that reference real transactions, real names and real account numbers. Warn your finance and customer-facing staff, and tighten payment verification. See What to do when a vendor asks to change their bank details.
Review the contract
- Breach notification timing and content the vendor owes you.
- Security obligations and audit rights.
- Who pays for notification, credit monitoring and investigation.
- Data return and deletion at the end of the relationship.
- Whether you should keep using the vendor, and on what conditions.
Yes, at least to assess. 'Potentially' often means the vendor can't rule it out. Ask what evidence they have, rotate access, and record your assessment. If the facts later confirm access, update your assessment and reporting decisions from there.
It's a useful input, but it was written for the vendor's purposes. Ask for the findings that affect you specifically, and check your own logs for activity from the vendor's connections during the breach window.
Related reading.
- PageUnder attack? Start hereIf something is wrong right now, this page tells you what to do in the next few minutes, what to avoid, and which step-by-step guide fits what you are seeing.
- GuideA vendor security questionnaire for small organizationsTwenty questions that tell you whether a vendor can be trusted with your data, how to read evasive answers, and how to turn the answers into contract terms.
- ServiceVendor privacy and security reviewsYour vendors hold your data, connect to your systems and can be the way an attacker gets in.
- ArticlePIPEDA Compliance Checklist for Canada: The IT Controls Small Businesses NeedA PIPEDA compliance checklist for Canadian small and mid-sized businesses: the IT safeguards, breach reporting and record-keeping the law expects, with practical notes…

Under attack right now?
Call before you reset passwords, wipe a laptop or pay anyone. A responder will help you contain the incident without destroying the evidence you will need later.
