This provision designates the advertiser as the data controller and Google as the data processor for personal data processed through Google Ads, establishing the legal roles and corresponding obligations of each party under applicable data protection law.
This analysis describes what Google Ads'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
This provision determines the allocation of data protection responsibilities between the advertiser and Google. The advertiser, as data controller, bears primary responsibility for establishing a lawful basis for processing, maintaining accurate privacy notices, and responding to data subject rights requests.
Under this clause, consumers whose data is processed through Google Ads campaigns are entitled to direct data subject rights requests to the advertiser as data controller. Google's processor obligations run to the advertiser, not directly to the individual consumer.
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"The parties acknowledge that for the purpose of Data Protection Legislation, the Customer is the controller and Google is the processor in respect of Customer Personal Data.— Excerpt from Google Ads's Google Ads Data Processing Terms
1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 28, which requires that processing by a processor on behalf of a controller be governed by a binding contract. The designation of roles determines which party bears which obligations under GDPR Articles 13-22 regarding data subject rights and Articles 33-34 regarding breach notification. Enforcement authority rests with EU supervisory authorities and, for UK operations, the ICO. 2) GOVERNANCE EXPOSURE: Medium. The controller designation places the advertiser in the position of bearing primary regulatory accountability for the lawfulness of processing, including the obligation to establish a valid legal basis before sharing data with Google. Advertisers who have not conducted a lawful basis assessment for their Google Ads data flows face compliance exposure. 3) JURISDICTION FLAGS: EU and UK advertisers face the most direct regulatory exposure under GDPR and UK GDPR respectively. California advertisers should evaluate whether the controller-processor characterization under this agreement aligns with the CCPA's business-service provider framework, as the two regimes use different terminology and definitions. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm that this DPA is incorporated by reference into or executed alongside the Google Ads Terms of Service, as GDPR Article 28(3) requires the processing agreement to be in writing. Audit rights provisions within the DPA should be reviewed to confirm they meet the requirements of the advertiser's own vendor management policies. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should update data inventories and records of processing activities under GDPR Article 30 to reflect Google as a named processor. Privacy notices should accurately describe the data controller's use of Google as a processor for advertising-related data processing.
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This provision determines the allocation of data protection responsibilities between the advertiser and Google. The advertiser, as data controller, bears primary responsibility for establishing a lawful basis for processing, maintaining accurate privacy notices, and responding to data subject rights requests.
Under this clause, consumers whose data is processed through Google Ads campaigns are entitled to direct data subject rights requests to the advertiser as data controller. Google's processor obligations run to the advertiser, not directly to the individual consumer.
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