Glean uses other companies (like cloud providers or AI model vendors) to deliver its service, and those companies may access your data. Glean is supposed to tell enterprise clients about changes to this list.
This analysis describes what Glean'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
Sub-processor visibility is a GDPR requirement and a practical security concern, since each sub-processor represents an additional party with access to potentially sensitive workplace data.
Interpretive note: Exact sub-processor disclosure language could not be confirmed from the truncated document; characterization reflects standard GDPR Article 28 processor obligations applicable to enterprise SaaS vendors.
Your workplace data processed by Glean may be accessible to Glean's sub-processors, such as cloud infrastructure or AI model providers, with the enterprise customer's awareness but typically without individual employee notification.
How other platforms handle this
Customer provides a general authorization for OpenAI to engage sub-processors. OpenAI will notify Customer of any new sub-processors by updating its sub-processor list. Customer may object to a new sub-processor by notifying OpenAI in writing within the objection period specified in the sub-processo...
Crusoe (Sees code data for inference): We manage Crusoe's compute for training some of our custom models, as well as hosting some of our custom models. Modal (Sees code data for inference): We manage Modal's compute for training some of our custom models, as well as hosting some of our custom models...
We use cookies, web beacons, and other tracking technologies to collect information about your browsing activities on our website. We may use third-party analytics providers such as Google Analytics to help us understand how users interact with our website. We may also work with third-party advertis...
Monitoring
Glean has changed this document before.
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"We use third-party service providers (sub-processors) to help us provide our services. These sub-processors may have access to personal data only as necessary to perform their functions. We maintain a list of sub-processors and will notify enterprise customers of material changes in accordance with our data processing agreements.— Excerpt from Glean's Glean Privacy Policy
(1) REGULATORY LANDSCAPE: GDPR Article 28(2) and (4) require processors to obtain controller authorization before engaging sub-processors and to impose equivalent data protection obligations on them by contract. Enterprise customers acting as controllers must authorize sub-processor use either generally (with notice of changes) or specifically. The DPA structure should address the sub-processor authorization model. (2) GOVERNANCE EXPOSURE: Medium. The policy's commitment to maintain a sub-processor list and notify of material changes is standard practice but requires enterprise customers to actively monitor for changes and assess whether new sub-processors are acceptable under their own risk frameworks. Changes involving AI model providers are particularly significant given the potential for sensitive data exposure. (3) JURISDICTION FLAGS: EU and UK enterprises face the strictest requirements under GDPR Article 28. Enterprise customers in regulated sectors (financial services, healthcare) may have contractual or regulatory restrictions on which sub-processors can access their data, requiring more granular controls than the policy's general commitment provides. (4) CONTRACT AND VENDOR IMPLICATIONS: The DPA should specify: whether sub-processor approval is general or specific; the notice period for new sub-processors (30 days is common); the enterprise's right to object to new sub-processors; and what happens if an objection cannot be accommodated (including termination rights). Enterprise customers should request and review Glean's current sub-processor list as part of vendor due diligence. (5) COMPLIANCE CONSIDERATIONS: Add Glean to the enterprise's vendor register and include sub-processor change monitoring as part of ongoing vendor management. Legal teams should confirm that Glean's sub-processor agreements meet GDPR Article 28(4) standards, either through direct verification or by requiring Glean to certify compliance.
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Sub-processor visibility is a GDPR requirement and a practical security concern, since each sub-processor represents an additional party with access to potentially sensitive workplace data.
Your workplace data processed by Glean may be accessible to Glean's sub-processors, such as cloud infrastructure or AI model providers, with the enterprise customer's awareness but typically without individual employee notification.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Glean.