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

Controller/Processor Dual Role by Product Line

High severity High confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The notice states that DocuSign acts as a data processor for eSignature customers, while asserting both processor and controller roles for CLM and Identity products depending on the processing activity, and directs data subject rights requests to the relevant customer where DocuSign acts as processor.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes the structural data governance relationship between DocuSign and its enterprise customers, determining which party bears primary responsibility for data subject rights responses, lawful basis determinations, and regulatory obligations depending on the product in use. The assertion of a dual controller/processor role for CLM and Identity products creates compliance dependencies that enterprise customers should reflect in their data processing agreements.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, individuals whose personal information is processed through DocuSign eSignature should direct data subject rights requests to the DocuSign customer (employer or requesting organization) rather than to DocuSign directly. For CLM and Identity products, DocuSign may independently determine processing purposes in certain circumstances, which affects the applicable rights framework.

Cross-platform context

See how other platforms handle Controller/Processor Dual Role by Product Line and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For example, in the context of Docusign eSignature, when a customer uploads contracts or other documents for review or signature, we act as a data processor and process the documents on the customer's behalf and in accordance with their instructions. In those instances, the customer is the data controller and is responsible for most aspects of the processing of the personal information. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certain circumstances (e.g., retention of transactional data to comply with Docusign's legal obligations).

Excerpt from DocuSign's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
DocuSign Privacy Statement
Entity
DocuSign
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014907
Document ID
CA-D-00198
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
db171ce667d98db1d8936fb125acc66e0d283cc7f0c00e08307fb68fd757092c
Analysis generated
July 9, 2026 06:43 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: DocuSign
Document: DocuSign Privacy Statement
Record ID: CA-P-014907
Captured: 2026-07-09 06:43:10 UTC
SHA-256: db171ce667d98db1…
URL: https://conductatlas.com/platform/docusign/docusign-privacy-statement/provision/CA-P-014907/controllerprocessor-dual-role-by-product-line/
Accessed: Sept. 8, 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 DocuSign's Controller/Processor Dual Role by Product Line clause do?

This provision establishes the structural data governance relationship between DocuSign and its enterprise customers, determining which party bears primary responsibility for data subject rights responses, lawful basis determinations, and regulatory obligations depending on the product in use. The assertion of a dual controller/processor role for CLM and Identity products creates compliance dependencies that enterprise customers should reflect in their data …

How does this clause affect you?

Under this provision, individuals whose personal information is processed through DocuSign eSignature should direct data subject rights requests to the DocuSign customer (employer or requesting organization) rather than to DocuSign directly. For CLM and Identity products, DocuSign may independently determine processing purposes in certain circumstances, which affects the applicable rights framework.

Is ConductAtlas affiliated with DocuSign?

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