DocuSign acts as a data controller when handling your data for its own purposes (like marketing), but acts as a data processor when handling data on behalf of business customers who use DocuSign's platform.
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
The dual role designation establishes different data governance responsibilities depending on the product used. When DocuSign acts as controller rather than solely as processor, it assumes independent obligations regarding data retention, use, and compliance with data protection regulations, which affects the scope of accountability between DocuSign and its customers.
Individual signers may have limited direct rights against DocuSign when data is controlled by a business customer; they should contact the sending organization to exercise their privacy rights in those contexts.
How other platforms handle this
When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...
If you are in the 'Designated Countries', LinkedIn Ireland Unlimited Company ('LinkedIn Ireland') will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services. If you are outside of the Designated Countries, LinkedIn Corporation will ...
This Privacy Policy does not apply where Anthropic acts as a data processor and processes personal data on behalf of commercial customers using Anthropic's Commercial Services – for example, your employer has provisioned you a Claude for Work account, or you're using an app that is powered on the ba...
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"When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. 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 DocuSign Privacy Statement
The controller/processor distinction has significant implications under GDPR Articles 4, 26, and 28; enterprise customers must ensure a valid Data Processing Agreement (DPA) is in place with DocuSign and that sub-processor obligations are flowed down appropriately.
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The dual role designation establishes different data governance responsibilities depending on the product used. When DocuSign acts as controller rather than solely as processor, it assumes independent obligations regarding data retention, use, and compliance with data protection regulations, which affects the scope of accountability between DocuSign and its customers.
Individual signers may have limited direct rights against DocuSign when data is controlled by a business customer; they should contact the sending organization to exercise their privacy rights in those contexts.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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