Your access tool is a vendor with a copy of your infrastructure map
Disclosure: I work on Tessera, which is self-hosted. That is the position I am arguing from, and the costs of that position are in the last section. Security questionnaires ask where customer data is processed. Access-control tools tend to get a shallow answer to that question, because people think of them as gatekeepers rather than as data processors. They are both. Here is what a hosted access broker necessarily knows about you. Your infrastructure inventory. Every registered target: hostnames, addresses, cluster endpoints, database names, environment labels. That is a map of your estate, and it is the document an attacker would most like to read before deciding where to spend effort. Your organisational structure. Who has access to what, which teams exist, who approves for whom, who was granted production access at 2am during an incident. Org charts are inferable from access graphs with unpleasant accuracy. Your session content, if recording is on. Every command, every query, every screen of output. That includes whatever your engineers pasted into a terminal, which — be honest about your own estate here — includes secrets sometimes. Timing. When your incidents happen, how long they last, who gets pulled in. That is commercially sensitive on its own. None of that requires the vendor to hold your credentials. It is the metadata, and the metadata is the part that survives every architectural mitigation. Where this shows up GDPR and processor chains. Session recordings contain personal data — identified individuals performing identified actions at identified times. A hosted vendor is a processor, which means a DPA, transfer mechanisms if data leaves the EEA, and a sub-processor list you have to monitor. It also means their sub-processors become your problem, which is a chain you do not control and cannot easily audit. Sector rules. Financial services, healthcare and public sector procurement in most European jurisdictions have specific requirements about where data