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
Mixpanel acts as a data processor on behalf of its customers (the controllers) when processing end user data through the Mixpanel analytics platform, and as a data controller with respect to data it collects about its own website visitors and account holders.
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...
Runway is considered the "data controller" of the "personal data" (as defined under the General Data Protection Regulation) we handle under this Privacy Policy. In other words, Runway is responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. The laws of ...
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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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