DocuSign plays two different legal roles depending on the situation: it controls your account and marketing data on its own terms, but processes document content strictly on behalf of the business that sent you the document.
This analysis describes what DocuSign'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
This distinction determines which privacy protections apply to your data. For document content, your rights may depend on the business that sent you the document rather than DocuSign directly, which could limit your direct recourse with DocuSign.
Previous version had no excerpt; current version adds detailed explanation of the distinction between controller and processor roles with specific examples.
View full change record →If you receive a document to sign from a company using DocuSign, that company, not DocuSign, is primarily responsible for how your document data is handled. Your privacy rights for that content must be exercised with the sending organization, not necessarily with DocuSign.
How other platforms handle this
Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
"Docusign may be a 'data controller' or a 'data processor' (or both) depending on the type of personal information and the context in which it is processed. When Docusign determines the purpose and means of processing personal information, we act as a data controller. When Docusign processes personal information on behalf of its customers pursuant to their instructions (for example, when customers use Docusign products to manage their own documents and data), we act as a data processor.Excerpt from DocuSign's Privacy Statement
(1) REGULATORY LANDSCAPE: The controller/processor distinction is a foundational GDPR concept governed by Articles 4, 24, and 28.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This distinction determines which privacy protections apply to your data. For document content, your rights may depend on the business that sent you the document rather than DocuSign directly, which could limit your direct recourse with DocuSign.
If you receive a document to sign from a company using DocuSign, that company, not DocuSign, is primarily responsible for how your document data is handled. Your privacy rights for that content must be exercised with the sending organization, not necessarily with DocuSign.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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