This analysis describes what ADP's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The obligation is qualified by 'strive to provide,' which is a best-efforts standard rather than a guarantee, and the commitment is calibrated to data sensitivity rather than uniform across all data.
ADP deleted the cookie preference management tool that previously allowed users to understand and control which cookies were placed on their devices, including functional, analytics, and advertising cookies. The removal eliminates the transparency mechanism through which users could consent to or opt out of different cookie categories. The practical effect depends on whether ADP has replaced this functionality elsewhere or whether cookies continue to be placed without equivalent granular user control.
View change record →ADP commits to a best-efforts standard of security scaled to data sensitivity, with Sensitive Personal Data receiving the greatest protective effort.
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"ADP will strive to provide security that is proportional to the sensitivity of the Personal Data being protected, with the greatest effort being focused on protecting Sensitive Personal Data...Excerpt from ADP's Privacy Statement
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The obligation is qualified by 'strive to provide,' which is a best-efforts standard rather than a guarantee, and the commitment is calibrated to data sensitivity rather than uniform across all data.
ADP commits to a best-efforts standard of security scaled to data sensitivity, with Sensitive Personal Data receiving the greatest protective effort.
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