Provision record
ADP · ADP Privacy Statement · View original document ↗

EEA client data transfers governed by BCR Privacy Code

High severity Explicit document language Common · 287 of 352 platforms
Stay ahead of the changes
Track ADP and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF

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

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 4429 other provisions on other platforms.

How other platforms handle this

Google Gemini Medium

The Gemini Apps Privacy Notice does not apply, and your Opal data, including feedback you provide, is processed per the Google Privacy Policy.

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

In the event you receive Oura-branded advertising sent to you by one of our third-party partners, please review the third-party's privacy policy for more information, and contact them with regard to any opt-out requests.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We will only transfer personal data pertaining to individuals located in the European Economic Area as permitted by the ADP Privacy Code for Client Data Processing Services.

Excerpt from ADP's 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-036742
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-036742
Captured: 2026-07-09 06:59:06 UTC
SHA-256: 68e06dd8e46c0e54…
URL: https://conductatlas.com/platform/adp/adp-privacy-statement/provision/CA-P-036742/eea-client-data-transfers-governed-by-bcr-privacy-code/
Accessed: Aug. 18, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does ADP's EEA client data transfers governed by BCR Privacy Code clause do?

The clause states: “We will only transfer personal data pertaining to individuals located in the European Economic Area as permitted by the ADP Privacy Code for Client Data Processing Services.”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 287 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.