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Instruction-Based Processing Limitation

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Document Record

What it is

This provision requires Google to process personal data only as directed by the advertiser, except where applicable law independently requires Google to act otherwise. The advertiser's instructions define the scope of permitted processing.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause establishes that the advertiser's documented instructions govern the scope of Google's processing activities. It places on the advertiser the obligation to provide clear, complete, and lawful instructions, and any processing outside those instructions would constitute a potential breach of the agreement.

Consumer impact (what this means for users)

This provision establishes that personal data processed through Google Ads is limited to the advertiser's instructions, meaning the categories of data processed and the purposes for which it is used are determined by the advertiser's configuration of Google Ads features and data inputs.

How other platforms handle this

Adyen Medium

If you are a California resident, you have the right to know what personal information we collect about you, the right to delete personal information we have collected from you, the right to opt-out of the sale or sharing of your personal information, the right to correct inaccurate personal informa...

Afterpay Medium

This Privacy Notice describes how Afterpay US, Inc. and affiliates ("Afterpay," "we," "us", and "our") collect, use, disclose, transfer, store, retain and otherwise process your personal information ("you", "your", and "customer") when you visit our website, download our app, apply for and use your ...

Anyscale Medium

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers and contractors to delete your personal information from their records. Correct inaccurate personal information that ...

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▸ View Original Clause Language DOCUMENT RECORD
"
Google will process Customer Personal Data only in accordance with Customer's documented instructions, unless required by applicable law to act without such instructions.

— Excerpt from Google Ads's Google Ads Data Processing Terms

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: This provision directly implements the GDPR Article 28(3)(a) requirement that a processor process personal data only on documented instructions from the controller. Where Google is required by EU or Member State law to process data without instructions, GDPR Article 28(3) requires Google to inform the controller of that legal requirement unless prohibited from doing so. The relevant enforcement authority is the applicable EU supervisory authority or UK ICO. 2) GOVERNANCE EXPOSURE: Medium. The advertiser's legal exposure depends on the accuracy and completeness of its documented instructions. Advertisers using features such as enhanced conversions, Customer Match, or remarketing audiences must ensure their instructions and data sharing practices align with their lawful basis and privacy disclosures. 3) JURISDICTION FLAGS: EU and UK advertisers face heightened exposure because the instruction requirement is a mandatory GDPR Article 28 element. Failure to document instructions adequately could undermine the legal basis for processing and create regulatory exposure during supervisory authority audits. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should evaluate whether the advertiser's implementation of Google Ads tags, conversion tracking pixels, and audience upload features constitutes adequately documented instructions. Instructions may be embedded in platform configuration rather than a separate document, which may be difficult to evidence during regulatory review. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain records documenting the specific Google Ads features enabled, the categories of data inputs configured, and the purposes for which each is used, to satisfy the documented instructions requirement and support GDPR Article 30 records of processing activities.

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Provision details

Document information
Document
Google Ads Data Processing Terms
Entity
Google Ads
Document last updated
May 20, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-012119
Document ID
CA-D-00859
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
385a446119d12e84c3972fbd564e6f0df6fdb0a6c3d481ba8938bcbb9dbd23b4
Analysis generated
May 20, 2026 12:57 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Google Ads
Document: Google Ads Data Processing Terms
Record ID: CA-P-012119
Captured: 2026-05-20 12:57:20 UTC
SHA-256: 385a446119d12e84…
URL: https://conductatlas.com/platform/google-ads/google-ads-data-processing-terms/instruction-based-processing-limitation/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Google Ads's Instruction-Based Processing Limitation clause do?

This clause establishes that the advertiser's documented instructions govern the scope of Google's processing activities. It places on the advertiser the obligation to provide clear, complete, and lawful instructions, and any processing outside those instructions would constitute a potential breach of the agreement.

How does this clause affect you?

This provision establishes that personal data processed through Google Ads is limited to the advertiser's instructions, meaning the categories of data processed and the purposes for which it is used are determined by the advertiser's configuration of Google Ads features and data inputs.

Is ConductAtlas affiliated with Google Ads?

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