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Controller vs. Processor Distinction for Enterprise Users

High severity Unique · 0 of 325 platforms
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This analysis describes what Duo Security'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 allocation of data controller responsibility clarifies the operational relationship and regulatory obligations between Cisco, the enterprise customer, and end users under data protection frameworks. It establishes that privacy right requests and data governance determinations flow through the enterprise customer as the primary data controller rather than through Cisco.

Consumer impact (what this means for users)

End users of Duo services deployed by enterprises must direct privacy requests to their employer or organization (the Duo customer) rather than to Cisco directly. The terms structure Cisco's liability and obligations around the enterprise customer's data controller status rather than direct relationships with individual users.

How other platforms handle this

Smartsheet Medium

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...

LinkedIn Medium

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 ...

Anthropic Medium

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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▸ View Original Clause Language DOCUMENT RECORD
"
When Cisco acts as a data processor on behalf of our customers (e.g., when a business uses Duo to authenticate their employees), the customer is the data controller and is responsible for determining how and why personal data is processed. In these cases, individuals should contact the business (our customer) directly to exercise their privacy rights.

— Excerpt from Duo Security's Duo Privacy

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Duo Privacy
Entity
Duo Security
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-004673
Document ID
CA-D-00696
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
76697f41b9802295d06a87d1528973ffe114cdf77c5e038c903ecb798ac000bc
Analysis generated
May 7, 2026 07:36 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duo Security
Document: Duo Privacy
Record ID: CA-P-004673
Captured: 2026-05-07 07:36:01 UTC
SHA-256: 76697f41b9802295…
URL: https://conductatlas.com/platform/duo-security/duo-privacy/controller-vs-processor-distinction-for-enterprise-users/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Duo Security's Controller vs. Processor Distinction for Enterprise Users clause do?

This allocation of data controller responsibility clarifies the operational relationship and regulatory obligations between Cisco, the enterprise customer, and end users under data protection frameworks. It establishes that privacy right requests and data governance determinations flow through the enterprise customer as the primary data controller rather than through Cisco.

How does this clause affect you?

End users of Duo services deployed by enterprises must direct privacy requests to their employer or organization (the Duo customer) rather than to Cisco directly. The terms structure Cisco's liability and obligations around the enterprise customer's data controller status rather than direct relationships with individual users.

Is ConductAtlas affiliated with Duo Security?

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