Glean · Glean Privacy Policy

Sub-Processor Disclosure and Data Processing Agreements

Medium severity
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What it is

Glean uses third-party vendors (sub-processors) to help deliver its services and requires those vendors to follow data protection rules, with a list of sub-processors available on request.

Consumer impact (what this means for users)

Your workplace data may be processed by multiple third-party vendors used by Glean, not just Glean itself, which expands the potential exposure of your personal information.

Cross-platform context

See how other platforms handle Sub-Processor Disclosure and Data Processing Agreements and similar clauses.

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Why it matters (compliance & risk perspective)

Enterprise customers need to know exactly which sub-processors handle their employees' data to assess risk and ensure GDPR Article 28 chain-of-custody compliance; a list that is only available 'on request' rather than prominently published creates transparency concerns.

View original clause language
When Glean engages sub-processors to process personal data on its behalf, Glean enters into data processing agreements with those sub-processors that require them to process personal data only as instructed and to implement appropriate security measures. A list of Glean's sub-processors is available upon request or through our website.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: GDPR Article 28(2) requires controllers to authorize use of sub-processors and mandates that processors impose equivalent data protection obligations on sub-processors by contract. Article 28(4) requires flow-down of all processor obligations. Failure to obtain prior written authorization for new sub-processors is a direct GDPR violation. UK GDPR imposes the same requirements. The ICO and EU DPAs (particularly the Irish DPC for US tech companies) enforce these obligations.

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Applicable agencies

  • FTC
    FTC Act Section 5 covers deceptive practices regarding data sharing with third parties; inadequate sub-processor disclosure and chain-of-custody failures can constitute unfair or deceptive data practices.
    File a complaint →

Provision details

Document information
Document
Glean Privacy Policy
Entity
Glean
Document last updated
April 29, 2026
Tracking information
First tracked
April 30, 2026
Last verified
April 30, 2026
Record ID
CA-P-004385
Document ID
CA-D-00505
Evidence Provenance
Source URL
Wayback Machine
SHA-256
bf35161360eff21ce3dcd83598198afb291214ea440a7d5ff199884f65aef203
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Glean | Document: Glean Privacy Policy | Record: CA-P-004385
Captured: 2026-04-30 09:15:11 UTC | SHA-256: bf35161360eff21c…
URL: https://conductatlas.com/platform/glean/glean-privacy-policy/sub-processor-disclosure-and-data-processing-agreements/
Accessed: May 2, 2026
Classification
Severity
Medium
Categories

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