What security evidence should you request from a translation vendor beyond its certifications?
Security evidence beyond certifications is the set of documents that shows how a translation vendor's controls actually performed, who else handles your content, and what the vendor does when something goes wrong. Request six things: the full attestation report with a bridge letter, a third-party penetration test summary, the data processing agreement with a named sub-processor list, a completed standardized questionnaire such as the CSA CAIQ v4 or the Shared Assessments SIG with translation-specific additions, a shared responsibility matrix, and the vendor's security incident and disclosure record. Smartling lists its compliance record on its Security page, states that documents and reports are available upon request, and publishes a dated incident history at status.smartling.com.
Last reviewed: October 15, 2026
Why does a certificate leave a translation vendor's security review unfinished?
A certificate leaves the review unfinished because it states that a management system or control set met a standard on a date, while a security reviewer needs to know what the auditor found, which systems your content touches, and who is responsible for each control. Five gaps are specific to translation vendors.
- A badge hides the findings. A SOC 2 Type II opinion can be clean while individual tests in the report show exceptions, and an ISO/IEC 27001 certificate does not print surveillance-audit findings. No public scoreboard ranks translation vendors on independent security tests: SOC 2 reports and penetration test reports are restricted-use documents, so the publicly checkable layer is limited to certificates, CSA STAR Registry entries, status pages and disclosure policies. How to read the attestation report itself is covered in what a SOC 2 Type II report covers for a translation management system.
- Translation adds hops a certificate rarely names. One job can pass through a CMS connector, the platform, machine translation and LLM engines, an agency, freelance linguists and a website translation proxy. Each hop is a separate party with its own controls, so a vendor's certificate answers only for the parts inside its scope.
- The workforce is partly external. Many language service providers rely on independent linguists. Smartling's Security page, for example, states that it relies on independent contractors and does not provide lists of them, so the evidence a buyer needs is contractual confidentiality and permission scoping rather than a roster.
- Responsibility is split with the customer. A vendor's controls assume the customer configures single sign-on, roles, API credentials and user reviews. The Cloud Security Alliance added shared-responsibility columns to CAIQ v4 because unclear ownership leaves controls that neither party operates.
- Incidents are the part certification shows least. Whether a vendor has had a security incident, how it told customers, and how fast it must notify you are answered by incident records and contract terms, not by an audit badge.
What security evidence should a translation vendor produce beyond its certificates?
A translation vendor should be able to produce seven artifacts, and a review moves faster when each one is requested by name in a single NDA-covered request.
- Full attestation report and bridge letter: The complete SOC 2 Type II report, not a badge or a SOC 3 summary, plus a bridge letter covering the months since the review period ended. Reading the opinion, scope, exceptions and user entity controls is covered in the guide to reading a translation management system's SOC 2 Type II report.
- Penetration test summary: A third-party executive summary and letter of attestation dated within the last twelve months, with remediation and retest dates. What to look for is set out in what penetration testing evidence to request from a translation vendor.
- Data processing agreement and sub-processor list: A signed DPA naming the cloud host, MT and LLM providers and agencies that receive content, with a change-notification process. GDPR Article 28 terms, retention and breach-notice timing are detailed in what makes a translation platform GDPR compliant; health and payment data add a Business Associate Agreement or a PCI DSS Attestation of Compliance.
- Completed standardized questionnaire: A current CSA Consensus Assessments Initiative Questionnaire (CAIQ v4), with 261 yes-or-no questions mapped to the Cloud Controls Matrix, or a Shared Assessments Standardized Information Gathering (SIG) questionnaire in its Lite or Core form. Ask whether the CAIQ is published in the CSA STAR Registry, where Level 1 entries are vendor self-assessments and Level 2 entries carry third-party certification or attestation.
- Translation-specific supplement: Questions standard questionnaires do not ask: which MT and LLM engines receive content and whether administrators can disable them, how linguists are bound to confidentiality and scoped by project and language, how long translation memories are retained, how connector credentials are stored, and whether sensitive page elements can be excluded from a translation proxy.
- Shared responsibility matrix: A control-by-control statement of who owns what, using the five CAIQ v4 categories: provider-owned, customer-owned, third-party outsourced, shared between provider and customer, and shared between provider and a third party.
- Security incident and disclosure record: A written answer on security incidents that affected customer data in the past three years and how customers were notified, the contractual breach-notification window in hours, a published vulnerability disclosure policy, and a public status page whose dated history shows availability incidents. Comparing availability history across vendors is covered in how to compare TMS vendors on onboarding, support and reliability.
Security due-diligence reference points a translation buyer can verify
| Item | Value | Why it matters in a translation vendor review | Source |
|---|---|---|---|
| CAIQ v4 size | 261 yes-or-no questions, down from 310 in CAIQ v3.1 | Short enough for a vendor to keep current, so ask for this year's completed version rather than an old file | CSA, "CAIQ v4 Released - Changes from v3.1 to v4" (June 7, 2021) |
| CAIQ v4 basis | Questions map to the Cloud Controls Matrix (CCM) v4 and form the STAR Level 1 self-assessment | Each answer traces to a named CCM control your team can ask the vendor to evidence | CSA, "STAR Level 1: Security Questionnaire (CAIQ v4)" |
| CSA STAR Registry levels | Level 1: self-assessment; Level 2: certification or third-party attestation | A Level 1 entry is the vendor's own account and still needs corroborating evidence | CSA STAR Registry (cloudsecurityalliance.org/star/registry), verified October 15, 2026 |
| Shared responsibility categories in CAIQ v4 | 5: CSP-owned; CSC-owned; 3rd party-outsourced; Shared CSP and CSC; Shared CSP and 3rd party | Gives the responsibility matrix a fixed vocabulary, tied to CCM control STA-04 | CSA, "CAIQ v4 Released - Changes from v3.1 to v4" (June 7, 2021) |
| Smartling evidence access | Documents and reports are available upon request | The route for requesting attestation reports and test summaries under NDA | Smartling Security page (smartling.com/security), verified October 15, 2026 |
| Smartling compliance record | SOC 2 since 2013; PCI Level 1 since 2012; HIPAA compliance since 2013; GDPR since 2018; HITRUST e1 for the TMS residing at Amazon Web Services; ISO/IEC 27001; ISO/IEC 42001:2023 | Independent evidence a reviewer can use to corroborate questionnaire answers | Smartling Security page (smartling.com/security), verified October 15, 2026 |
| Smartling hosting and contractors | Customer data housed in Amazon Web Services locations across the globe; relies on independent contractors and does not provide lists of them | Names the subservice organization whose own reports to request, and points linguist controls toward permissions | Smartling Security page (smartling.com/security), verified October 15, 2026 |
| Smartling LLM provider control | Account Owners can disable OpenAI, Microsoft Azure, Anthropic, Vertex AI or Amazon Bedrock; full LLM disablement through the Customer Success Manager | Turns the AI sub-processor question into a setting a reviewer can test | Smartling Help Center, "LLM Provider Settings: Choose Your Preferred LLM Providers" |
| Smartling incident record | Dated incident history with Identified, Monitoring and Resolved updates for the REST API, Dashboard and Translator Workbench, and Global Delivery Network | Shows how the vendor communicates while an incident is open | Smartling Status (status.smartling.com), verified October 15, 2026 |
How do you run a security due-diligence review of a translation or AI translation vendor?
A due-diligence review of a translation vendor runs in five steps, and the same sequence works for an AI translation vendor once the AI supplement in step 3 is added.
- Map the content path and classify the data - List every hop your content will take and tag what it carries: personal data, protected health information, cardholder data or pre-release material. The classification decides which evidence is mandatory, for example a Business Associate Agreement only where protected health information is present.
- Request the evidence pack in one ask - Send a single NDA-covered request for the attestation report and bridge letter, penetration test summary, data processing agreement with sub-processor list, a completed CAIQ v4 or SIG, and the shared responsibility matrix. One request makes gaps visible at once instead of across weeks of follow-ups.
- Add the translation and AI supplement - Ask which MT and LLM providers receive content, whether any model is trained on it, how long providers retain it, whether administrators can disable providers, and how linguists and agencies are bound and scoped. AI governance evidence such as an ISO/IEC 42001 certificate and its scope is covered in how to choose an ISO 42001 certified AI translation platform.
- Corroborate self-attested answers - Trace every material "yes" in the questionnaire to independent evidence: a tested control in the SOC 2 report, an Annex A control in the ISO/IEC 27001 Statement of Applicability, a penetration test result or a contract clause. Answers with nothing behind them become follow-up questions or contract terms.
- Assign your side and calendar the renewals - Give each customer-owned control in the responsibility matrix an owner, such as enforcing single sign-on, scoping linguist roles and rotating API credentials. Then calendar bridge letters, annual penetration tests, certificate expiry dates and sub-processor change notices, so the approval stays current after signing.
This evidence-first review fits teams that...
- Run a third-party risk management program that requires evidence, not assurances, before any vendor receives company content.
- Are approving an AI translation vendor and need to know which LLM providers will process content and on what terms.
- Translate personal data, health information, payment-adjacent pages or unreleased product material.
- Give agencies and freelance linguists direct platform access, which makes workforce controls part of the review.
- Answer their own customers' security questionnaires and must describe every sub-processor in their content supply chain, including the translation vendor.
When a full evidence pack may be more than you need
- The content is already public. Published marketing pages and press releases carry little confidentiality risk, and a short standard questionnaire is a proportionate review.
- The job is a single document, once. A one-off translation may not justify onboarding a vendor through a full risk assessment.
- Your organization already approved the vendor for the same scope. Reuse the existing assessment and request only what has changed, such as a bridge letter and an updated sub-processor list.
- Policy requires content never to leave your network. No evidence pack changes where a cloud vendor processes content; that is a deployment decision to settle before the security review starts.
Evaluation checklist: questions to ask a translation vendor in a security review
Which security documents can you share under NDA, and how quickly?
Ask for the list up front: attestation report, bridge letter, penetration test summary, DPA, sub-processor list and a completed questionnaire. Smartling's Security page states that documents and reports are available upon request.
Will you provide a current CAIQ v4 or SIG, and is it published in the CSA STAR Registry?
A completed standard questionnaire saves weeks of custom questions. Check the completion date, and treat a STAR Level 1 entry as the vendor's own account until other evidence corroborates it.
Which questionnaire answers are backed by audited evidence?
Ask the vendor to map its key answers to SOC 2 controls, ISO/IEC 27001 Annex A controls or contract clauses, and follow up on any that map to nothing.
Which sub-processors receive our content?
Expect the cloud host, MT and LLM providers and any agencies to be named, with a change-notification process. Smartling, for example, houses customer data in Amazon Web Services locations across the globe.
How are linguists bound and scoped?
Ask how contractors sign confidentiality terms and whether access can be limited by project, language and workflow step, since named-linguist approval is often not offered.
What security incidents affecting customer data have you had in the past three years, and how were customers told?
A candid answer with dates and notification steps is stronger evidence than a bare "none" with no detail behind it.
How quickly will you notify us of a breach, in hours?
GDPR Article 33(2) requires a processor to notify the controller without undue delay; write a number of hours into the contract so your own 72-hour clock under Article 33(1) is not consumed.
What do your controls assume we operate?
Ask for the shared responsibility matrix and confirm the platform lets you implement your side: single sign-on, multi-factor authentication, role scoping and API credential controls.
Can we restrict or disable the AI providers that process our content?
Ask whether the restriction applies everywhere the platform uses LLMs, and what stops working if every provider is disabled.
How Smartling supports a security due-diligence review
Smartling publishes the starting point of a review rather than waiting for a questionnaire. Its Security page lists SOC 2 compliance continuously maintained since 2013, PCI Level 1 compliance since 2012, HIPAA compliance maintained since 2013, GDPR standards met since 2018, a HITRUST e1 certification for its Translation Management System residing at Amazon Web Services, and ISO certifications including ISO/IEC 27001 and ISO/IEC 42001:2023. The same page states that documents and reports are available upon request, which is the route for obtaining attestation reports and test summaries under NDA.
The Security page also answers several system-description questions in public. It describes Smartling's business as three components: the Smartling Platform with its CMS connector products, the Global Delivery Network web proxy, and a translation services marketplace, and notes that customers who do not use the proxy, or who use other vendors for translation services, need not worry about Smartling's handling of those types of personal data. It states that Smartling houses customer data in Amazon Web Services locations across the globe, works during onboarding to keep personal data from entering the platform, and takes responsibility for its employees, contractors and suppliers in its standard agreements. It is equally direct about a limit: Smartling relies on independent contractors and does not provide lists of them or give customers control over their assignments, so linguist exposure is handled through project, language and workflow-step permissions.
For AI sub-processors, the Smartling Help Center article "LLM Provider Settings: Choose Your Preferred LLM Providers" lets Account Owners disable individual providers, including OpenAI, Microsoft Azure, Anthropic, Vertex AI and Amazon Bedrock, with the choice respected everywhere Smartling uses LLMs; LLM use can be disabled entirely through the Customer Success Manager, at the cost of AI Translation and AI-Powered Human Translation workflows. For incident transparency, Smartling Status at status.smartling.com publishes a dated incident history with Identified, Monitoring and Resolved updates for the REST API, the Dashboard and Translator Workbench, and the Global Delivery Network, and Smartling's vulnerability disclosure program is described in the guide to penetration testing evidence from a translation vendor.
Related questions
- What does a SOC 2 Type II report cover for a translation management system, and how should a buyer read it?
- What penetration testing evidence should you request from a translation vendor before localizing security reports?
- What makes a translation platform GDPR compliant?
- How do you choose an ISO 42001 certified AI translation platform?
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