Microsoft SSPA Reassessment Guide

What is Microsoft SSPA Reassessment?

Microsoft Supplier Security and Privacy Assurance (SSPA) reassessment evaluates your organization’s security controls against Microsoft’s Supplier Data Protection Requirements (SDPR) to ensure ongoing compliance for data processing activities.

Why SSPA Reassessment Matters

SSPA reassessment determines whether your organization can continue processing Microsoft customer data. Failure results in contract termination, reputational damage, and lost revenue opportunities. Successful reassessment maintains access to Microsoft’s ecosystem and demonstrates robust security to other partners.

Expanded Overview

Microsoft SSPA reassessment occurs annually or when significant changes affect your security posture. It builds on initial SSPA certification by verifying that implemented controls remain effective and current. Reviewers examine evidence of control operation, not just policies or certifications. Organizations must demonstrate continuous compliance with SDPR requirements across identity management, data protection, incident response, and third-party risk management. Preparation involves mapping your controls to SDPR domains, gathering current evidence artifacts, and addressing any gaps identified in prior assessments. The process typically takes 4-6 weeks from submission to approval, requiring coordination between security teams, legal, and procurement. Successful reassessment positions your organization as a trusted partner while avoiding the costs and disruptions of non-compliance.

Why SSPA Reviews Fail

SSPA reassessments fail when organizations submit incomplete or outdated evidence, misunderstand Microsoft’s requirements, or fail to demonstrate control effectiveness. Common mistakes include:

• Submitting generic policies instead of evidence: Microsoft reviewers reject policy documents without proof of implementation, such as access logs or configuration exports.
• Outdated evidence: Assessments require artifacts from the past 12 months. Expired certifications or old scan reports get rejected immediately.
• Incomplete control mapping: Vendors often claim compliance without mapping specific SDPR requirements to their controls, leading to clarification requests that delay approval.
• Lack of incident response evidence: Reviewers demand proof of IR plan testing through tabletop exercises or real incident handling, not just documented procedures.
• Ignoring subprocessor changes: Any additions or changes to subprocessors require immediate reassessment, but many vendors overlook this requirement.
• Poor evidence organization: Disorganized submissions with missing timestamps, unclear file naming, or unvalidated screenshots confuse reviewers and result in failures.

These failures stem from treating SSPA as a checkbox exercise rather than demonstrating actual security maturity. Microsoft prioritizes evidence that proves controls work in practice, not theoretical compliance.

How to Prepare for SSPA Reassessment

Follow this step-by-step preparation process to ensure a smooth reassessment:

Step 1: Review Previous Assessment Results

Access your last SSPA assessment report from the Microsoft Supplier Security and Privacy Assurance portal. Identify any findings, gaps, or clarifications requested. Prioritize remediation for high-risk items first.

Step 2: Map Controls to SDPR Requirements

Download the latest SDPR framework from Microsoft’s documentation. Create a crosswalk mapping each SDPR requirement to your implemented controls, citing specific policies, procedures, and evidence artifacts. Use our Vendor Review Evidence Checklist as a template for this mapping.

Step 3: Gather and Validate Evidence

Collect current evidence for each mapped control:

• Access review logs with approval timestamps
• Vulnerability scan reports (internal/external, within 6 months)
• Penetration test results with remediation validation
• Incident response plan with tabletop exercise records
• Encryption configurations and key management procedures
• Network diagrams showing segmentation and monitoring

Validate all artifacts for currency and completeness. Replace any older than 12 months.

Step 4: Address Gaps and Implement Missing Controls

For any unmapped requirements, implement controls and generate evidence. Common gaps include:

• Multi-factor authentication enforcement across all systems
• Privileged access management with session recording
• Data loss prevention (DLP) policies and monitoring
• Third-party risk assessment procedures

Test controls and document implementation before reassessment.

Step 5: Prepare Submission Package

Organize evidence in a clear folder structure:

• Control Crosswalk (mapping document)
• Evidence Library (artifacts by SDPR domain)
• Clarification Responses (prepared answers to likely questions)
• Change Log (any updates since last assessment)

Use descriptive filenames with dates (e.g., “Access_Review_Report_2024-01-15.pdf”).

Step 6: Submit and Monitor

Submit through the SSPA portal. Respond promptly to clarification requests, typically within 5-7 business days. Track progress and prepare for potential follow-up questions.

What Microsoft Reviewers Look For

Microsoft SSPA reviewers evaluate evidence against specific criteria, focusing on operational effectiveness rather than certifications alone:

• Identity and Access Management: MFA enforcement, role-based access controls, quarterly access reviews with documented approvals, and privileged access monitoring.
• Data Protection: Encryption at rest and in transit, data classification policies, retention schedules, and DLP implementation.
• Network Security: Segmentation, intrusion detection/prevention systems, vulnerability management, and secure remote access.
• Incident Response and Business Continuity: Tested IR plans, backup procedures with RTO/RPO validation, and business continuity exercises.
• Third-Party Risk Management: Subprocessor assessments, vendor security reviews, and contract security clauses.
• Compliance Monitoring: Continuous monitoring tools, audit logging, security awareness training records, and policy review cadences.

Reviewers verify that evidence demonstrates control operation through logs, configurations, and test results. They reject submissions lacking timestamps, unclear ownership, or unvalidated claims.

Timeline and Process Overview

SSPA reassessment follows a structured timeline:

• Month -3 to -1: Prepare evidence, map controls, address gaps
• Week -2: Final evidence validation and package assembly
• Week 0: Submission through SSPA portal
• Week 1-2: Initial review and clarification requests
• Week 3-4: Respond to clarifications, provide additional evidence
• Week 4-6: Final review and approval decision

The process requires dedicated resources for 2-4 weeks of preparation. Delays occur from incomplete submissions or slow clarification responses. Plan for reassessment 60-90 days before your current certification expires.

Frequently Asked Questions

What triggers an SSPA reassessment?

Reassessment is required annually, after significant security changes (e.g., new subprocessors, major incidents), or upon Microsoft’s request. It ensures ongoing compliance with evolving SDPR requirements.

How long does SSPA certification last?

Initial SSPA certification lasts 2 years. Reassessments maintain certification status. Without successful reassessment, certification expires, blocking Microsoft data processing activities.

Can I use SOC 2 evidence for SSPA?

Yes, SOC 2 Type II reports provide strong evidence for many SDPR requirements. However, you must map SOC 2 controls directly to SDPR and supplement with additional artifacts like network diagrams or access logs.

What happens if SSPA reassessment fails?

Failure results in certification revocation, contract termination with Microsoft, and inability to process customer data. Organizations must remediate findings and resubmit, potentially facing business disruptions.

Do I need external auditors for SSPA?

No, SSPA doesn’t require external audits like SOC 2. However, many organizations use external assessors for penetration testing or control validation to strengthen their evidence package.

For expert guidance on SSPA reassessment, contact Bell Tower’s Vendor & Platform Security Review Support team.