ADP · ADP Privacy Statement · View original document ↗

Third-party transfers require written data protection contract

High severity High confidence Explicitdocumentlanguage Common · 289 of 352 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause requires a written contractual guarantee of equivalent data protection before any Personal Data transfer, establishing a minimum standard that external and internal processors must meet.

Recent Activity

This document changed recently

Medium May 1, 2026

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 →

Consumer impact (what this means for users)

Your Personal Data will only be transferred by ADP to a Third Party or Internal Processor when a written contract guaranteeing the same level of data protection is in place.

How other platforms handle this

Google Gemini Medium

Third-party apps use data from Gemini consistent with their own privacy policies and terms.

Adobe Medium

we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...

Oura Medium

We also require these service providers to protect your personal information to at least the same standards that we do.

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Monitoring

ADP has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
ADP will only transfer Personal Data to a Third Party or to an Internal Processor if a written contract has been entered into with the ADP Group Company ensuring that the same level of data protection will be applied...

— Excerpt from ADP's ADP Privacy Statement

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
ADP Privacy Statement
Entity
ADP
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-036707
Document ID
CA-D-00302
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
68e06dd8e46c0e54a6f4f1c94bfa5a30c8e2c714e4db7e4e054bc0413797dfc6
Analysis generated
July 9, 2026 06:59 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: ADP
Document: ADP Privacy Statement
Record ID: CA-P-036707
Captured: 2026-07-09 06:59:06 UTC
SHA-256: 68e06dd8e46c0e54…
URL: https://conductatlas.com/platform/adp/adp-privacy-statement/provision/CA-P-036707/third-party-transfers-require-written-data-protection-contract/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does ADP's Third-party transfers require written data protection contract clause do?

This clause requires a written contractual guarantee of equivalent data protection before any Personal Data transfer, establishing a minimum standard that external and internal processors must meet.

How does this clause affect you?

Your Personal Data will only be transferred by ADP to a Third Party or Internal Processor when a written contract guaranteeing the same level of data protection is in place.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with ADP?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by ADP.