Fastly · Fastly Privacy Policy · View original document ↗

Controller vs. Processor Dual Role

High severity Rare · 2 of 325 platforms
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This analysis describes what Fastly'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)

The distinction between controller and processor roles carries different legal obligations under data protection frameworks such as GDPR. As a controller, Fastly bears primary responsibility for lawfulness of processing; as a processor, it operates under customer direction and instruction. This dual-role designation clarifies Fastly's legal accountability and obligations in different operational contexts.

Consumer impact (what this means for users)

Customers using Fastly's content delivery services operate under a processor relationship where Fastly processes data according to customer instructions, while Fastly's collection of data for its own business operations (website management, customer relationship management) operates under a controller relationship where Fastly determines processing purposes and means.

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...

DocuSign Medium

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 certa...

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 ...

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▸ View Original Clause Language DOCUMENT RECORD
"
Fastly acts as a 'data controller' when we determine the purposes and means of the processing of personal data, such as when we collect and use personal data to operate our website, manage customer relationships, and conduct our business operations. Fastly acts as a 'data processor' when we process personal data on behalf of our customers pursuant to their instructions, such as when our customers use our services to deliver content to their end users.

— Excerpt from Fastly's Fastly Privacy Policy

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
Fastly Privacy Policy
Entity
Fastly
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-006994
Document ID
CA-D-00676
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
cbddaed40180df2ad9f739ec146b4892475952ea75220d4fd8a1912da0062603
Analysis generated
May 8, 2026 15:45 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Fastly
Document: Fastly Privacy Policy
Record ID: CA-P-006994
Captured: 2026-05-08 15:45:23 UTC
SHA-256: cbddaed40180df2a…
URL: https://conductatlas.com/platform/fastly/fastly-privacy-policy/controller-vs-processor-dual-role/
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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Frequently Asked Questions

What does Fastly's Controller vs. Processor Dual Role clause do?

The distinction between controller and processor roles carries different legal obligations under data protection frameworks such as GDPR. As a controller, Fastly bears primary responsibility for lawfulness of processing; as a processor, it operates under customer direction and instruction. This dual-role designation clarifies Fastly's legal accountability and obligations in different operational contexts.

How does this clause affect you?

Customers using Fastly's content delivery services operate under a processor relationship where Fastly processes data according to customer instructions, while Fastly's collection of data for its own business operations (website management, customer relationship management) operates under a controller relationship where Fastly determines processing purposes and means.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.

Is ConductAtlas affiliated with Fastly?

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