ADP · ADP Privacy Statement · View original document ↗

Client employee data processed only per client instructions

High severity High confidence Explicitdocumentlanguage Common · 279 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 limits ADP's authority to process personal data to instructions or permissions from the employer or the individual, restricting ADP's independent discretion over data use.

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 collected and processed by ADP when your employer, prospective employer, or you have instructed or permitted it.

How other platforms handle this

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

Square Medium

we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
ADP will collect and process your personal data only as instructed or permitted by our Client (your employer or prospective employer) or you.

— Excerpt from ADP's ADP Privacy Statement

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal

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-036724
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-036724
Captured: 2026-07-09 06:59:06 UTC
SHA-256: 68e06dd8e46c0e54…
URL: https://conductatlas.com/platform/adp/adp-privacy-statement/provision/CA-P-036724/client-employee-data-processed-only-per-client-instructions/
Accessed: July 12, 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 Client employee data processed only per client instructions clause do?

This clause limits ADP's authority to process personal data to instructions or permissions from the employer or the individual, restricting ADP's independent discretion over data use.

How does this clause affect you?

Your personal data will only be collected and processed by ADP when your employer, prospective employer, or you have instructed or permitted it.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 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.