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Data Processing Addendum Incorporation

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Document Record

What it is

If your organization processes personal data using Atlassian products, a separate Data Processing Addendum governs how that data is handled, and it is legally part of your agreement with Atlassian.

This analysis describes what Atlassian'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)

The DPA is the operative document for GDPR and CCPA compliance purposes, and its terms govern data controller and processor obligations, sub-processor authorization, and cross-border transfer mechanisms for personal data processed through Atlassian products.

Interpretive note: The full scope of obligations depends on the terms of the separately published DPA, which is incorporated by reference but not reproduced in the base agreement text analyzed here.

Consumer impact (what this means for users)

Organizations processing personal data in Atlassian products are subject to the terms of the Data Processing Addendum, which governs how Atlassian handles that data and what sub-processors may have access to it.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Access Atlassian's Data Processing Addendum at the legal documentation page, review the sub-processor list and cross-border transfer mechanisms, and ensure the DPA is properly executed as part of your organization's vendor compliance process.

How other platforms handle this

Miro Medium

Miro's processing of personal data on behalf of customers is governed by the Customer Data Processing Addendum, which is incorporated into these Terms by reference. A current list of subprocessors used by Miro is available at miro.com/legal/subprocessors-list/ and is updated from time to time.

Meta Medium

We may access, preserve, and share information with regulators, law enforcement, or others if we believe it is reasonably necessary to: detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others, including as part of investigations; and prevent death or imminen...

Mistral AI Medium

Customer authorized Mistral AI to transfer Personal Data to any country deemed to have an adequate level of data protection by the European Commission. Customer also authorizes Mistral AI to perform International Data Transfers to (a) on the basis of adequate safeguards in accordance with Applicable...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
To the extent Customer's use of the products involves the processing of personal data subject to applicable data protection laws (including the GDPR and CCPA), the parties' respective rights and obligations with respect to such processing are set forth in the Data Processing Addendum, which is incorporated into this Agreement by reference.

— Excerpt from Atlassian's Atlassian Cloud Terms

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The DPA incorporation directly engages GDPR (for EU/EEA and UK customers), CCPA and CPRA (for California-based customers), and applicable national data protection laws globally. The relevant enforcement authorities are EU data protection authorities through the European Data Protection Board, the UK Information Commissioner's Office, and the California Privacy Protection Agency. The DPA governs the legal basis for processing, sub-processor authorization, data subject rights mechanisms, and cross-border transfer safeguards. GOVERNANCE EXPOSURE: High for organizations in regulated industries or those processing sensitive personal data categories. The DPA must be reviewed and executed separately from the main agreement; failure to do so may create gaps in GDPR controller-processor documentation requirements. JURISDICTION FLAGS: EU and UK customers must confirm that the DPA includes appropriate Standard Contractual Clauses (SCCs) and, where applicable, transfer impact assessments for cross-border data transfers to Atlassian entities outside the EEA. Australian customers should assess alignment with the Privacy Act and Australian Privacy Principles. Canadian customers should assess alignment with PIPEDA and provincial privacy laws. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm the DPA is executed, that the sub-processor list has been reviewed and accepted, and that notification mechanisms for sub-processor changes are operational. The DPA should be reviewed for audit rights, data breach notification timelines, and data retention and deletion obligations. COMPLIANCE CONSIDERATIONS: Privacy and legal teams should maintain a current copy of the executed DPA, update data processing records of activities to reflect Atlassian as a sub-processor, and review the sub-processor list against their own vendor risk management program. Any changes to Atlassian's sub-processor list should trigger a review of the organization's data flow documentation.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over data protection and privacy practices of US-based companies and may investigate failures to honor stated data processing commitments.
    File a complaint →
  • State AG
    State attorneys general in California and other states with comprehensive privacy laws have enforcement authority over data processor obligations and CCPA compliance.
    File a complaint →

Applicable regulations

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

Provision details

Document information
Document
Atlassian Cloud Terms
Entity
Atlassian
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 12, 2026
Record ID
CA-P-010943
Document ID
CA-D-00707
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
43d2f9eb25e260f7f82440abad02e2eba835af6870815ec9bb7ba9cddb25b8ec
Analysis generated
May 8, 2026 01:00 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Atlassian
Document: Atlassian Cloud Terms
Record ID: CA-P-010943
Captured: 2026-05-08 01:00:52 UTC
SHA-256: 43d2f9eb25e260f7…
URL: https://conductatlas.com/platform/atlassian/atlassian-cloud-terms/data-processing-addendum-incorporation/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Atlassian's Data Processing Addendum Incorporation clause do?

The DPA is the operative document for GDPR and CCPA compliance purposes, and its terms govern data controller and processor obligations, sub-processor authorization, and cross-border transfer mechanisms for personal data processed through Atlassian products.

How does this clause affect you?

Organizations processing personal data in Atlassian products are subject to the terms of the Data Processing Addendum, which governs how Atlassian handles that data and what sub-processors may have access to it.

Is ConductAtlas affiliated with Atlassian?

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