When you use an AI model from a company other than Amazon through Bedrock, your data may be sent to that company and governed by their separate rules, not just AWS's rules.
This analysis describes what AWS Bedrock'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 clause creates a bifurcated governance structure in which data processing for third-party models falls outside AWS's direct control and contractual scope, requiring users to separately evaluate and comply with each model provider's distinct terms, privacy policies, and data handling practices.
The updated terms establish new data-sharing mechanisms for users of Anthropic models on Amazon Bedrock. Specifically, AWS now explicitly authorizes notification to Anthropic of metadata present in requests sent to certain Anthropic products (e.g., Claude Code, computer use features), enabling Anthropic to conduct product-level usage attribution. Additionally, the terms introduce AWS WAF AI traffic monetization, which permits AWS to facilitate payment transactions between content publishers and buyers by sharing pricing, payment, and configuration information with payment providers and facilitators; the updated terms clarify that AWS does not provide regulated financial services and is not a party to fund flows, and that users' interactions with payment providers are governed by separate terms between the user and those parties. Users employing these features should review what metadata may be embedded in their requests and understand their own obligations to payment providers.
View change record →The updated terms establish that customers operating Amazon RDS databases on end-of-life software versions are now required to upgrade to supported versions. The agreement authorizes AWS to scan extension code used with Trusted Language Extensions for security and performance purposes, and establishes that extension code constitutes customer content. AWS disclaims responsibility for service failures caused by extensions or end-of-life database software. If a customer does not upgrade before an engine reaches end of life, AWS may snapshot the customer's data and delete the instance or cluster running the unsupported software, after providing prior notice of the engine end-of-life date.
View change record →The updated terms establish new operational requirements for any organization using Amazon Connect Talent to make or inform employment decisions. Customers must now obtain legally adequate privacy notices and consents from job applicants before their data is processed by the service. The terms require customers to review all AI output before making hiring decisions, implement processes for applicants to request information about the AI's role in decisions, and ensure their use of the tool complies with applicable labor, anti-discrimination, disability, data privacy, AI, wiretap, recordkeeping, and biometrics laws. Customers can configure an AI services opt-out policy through AWS Organizations to prevent their data from being used to train or improve AWS AI technologies.
View change record →Using third-party foundation models through Bedrock means your prompts, documents, and outputs may leave AWS's direct control and become subject to terms you have not directly negotiated, which could affect your data protection, confidentiality, and compliance posture.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...
We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.
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"If you use a third-party model, your inputs and outputs may be processed by the third-party model provider, and such processing will be subject to that provider's terms and conditions.— Excerpt from AWS Bedrock's AWS Service Terms
REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28 on sub-processor relationships and the obligation for data controllers to ensure sub-processors provide sufficient guarantees. It also implicates CCPA requirements for businesses relying on service provider exemptions, as onward data flows to third-party model providers may require additional contractual and disclosure steps. EU AI Act obligations for deployers of high-risk AI systems may also be triggered depending on the model and use case. GOVERNANCE EXPOSURE: High. The provision creates a layered data processing chain where the primary customer agreement with AWS does not fully govern the end-to-end data flow. Customers must independently assess each third-party model provider's terms, and the absence of a consolidated compliance framework covering all available models represents a significant due diligence burden for enterprise customers. JURISDICTION FLAGS: EU/EEA customers face the highest exposure, as GDPR requires documented sub-processor agreements and may require updated Records of Processing Activities (RoPA) for each third-party model provider used. California businesses should assess whether these onward transfers satisfy CCPA service provider chain requirements. Healthcare customers handling PHI should confirm whether third-party model providers have executed BAAs and whether Bedrock's BAA coverage extends to these providers. CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should maintain an up-to-date inventory of third-party model providers available through Bedrock and the applicable terms for each. Enterprise contracts with AWS should address whether AWS provides contractual flow-down protections to third-party model providers or whether customers must contract directly. Standard B2B agreements built on the assumption of AWS-only data processing will need review if third-party models are in use. COMPLIANCE CONSIDERATIONS: Data mapping exercises should capture third-party model provider data flows as distinct processing activities. Consent mechanisms and privacy notices may need updating to disclose these onward transfers. Vendor risk assessments should be conducted for each third-party model provider in the customer's Bedrock deployment.
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The clause creates a bifurcated governance structure in which data processing for third-party models falls outside AWS's direct control and contractual scope, requiring users to separately evaluate and comply with each model provider's distinct terms, privacy policies, and data handling practices.
Using third-party foundation models through Bedrock means your prompts, documents, and outputs may leave AWS's direct control and become subject to terms you have not directly negotiated, which could affect your data protection, confidentiality, and compliance posture.
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