This provision authorizes Google to use sub-processors to assist with data processing and requires Google to provide advance notice of any additions or replacements to its sub-processor list, giving advertisers an opportunity to raise objections before changes take effect.
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 clause establishes the mechanism by which advertisers are notified of sub-processor changes and granted an objection right. Advertisers must actively monitor Google's sub-processor notifications to exercise any objection rights within the designated window.
Interpretive note: The document does not specify the objection window duration or the procedure following a valid advertiser objection, creating operational uncertainty about the practical enforceability of the objection right.
Under this clause, personal data processed through Google Ads may be shared with Google's sub-processors as listed in Google's sub-processor documentation. Advertisers receive advance notice of sub-processor changes and retain an objection right, but individual consumers do not have a direct mechanism under this clause to object to sub-processor engagement.
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"Google may engage sub-processors to assist in fulfilling its obligations consistent with this Agreement. Google will provide the Customer with prior notice of any intended changes concerning the addition or replacement of sub-processors, giving the Customer the opportunity to object to such changes.— Excerpt from Google Ads's Google Ads Data Processing Terms
1) REGULATORY LANDSCAPE: This provision implements the GDPR Article 28(2) requirement that a processor not engage a sub-processor without prior specific or general written authorization from the controller. The use of general authorization with a notification-and-objection mechanism is a common and GDPR-compliant approach. Enforcement authority rests with EU supervisory authorities and, for UK operations, the ICO. 2) GOVERNANCE EXPOSURE: Medium. Advertisers who do not actively monitor Google's sub-processor change notifications may inadvertently waive objection rights. The practical consequence of a valid objection is unclear from the document alone, as the agreement does not specify the outcome procedure if an advertiser objects and Google proceeds with the sub-processor change. 3) JURISDICTION FLAGS: EU and UK advertisers must ensure their own records of processing activities under GDPR Article 30 are updated to reflect current Google sub-processors. Downstream transfer obligations apply where sub-processors are located outside the EEA or UK, requiring transfer mechanism evaluation. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should establish a process for monitoring Google's sub-processor change notifications, which are typically published at a URL referenced in the DPA. The agreement should be reviewed to confirm whether the notification method, objection window, and consequences of objection are specified with sufficient clarity for operational compliance purposes. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should identify where Google sub-processors are located, evaluate whether transfers to those sub-processors are covered by Standard Contractual Clauses or other transfer mechanisms, and document this evaluation in transfer impact assessments maintained under post-Schrems II EDPB guidance.
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This clause establishes the mechanism by which advertisers are notified of sub-processor changes and granted an objection right. Advertisers must actively monitor Google's sub-processor notifications to exercise any objection rights within the designated window.
Under this clause, personal data processed through Google Ads may be shared with Google's sub-processors as listed in Google's sub-processor documentation. Advertisers receive advance notice of sub-processor changes and retain an objection right, but individual consumers do not have a direct mechanism under this clause to object to sub-processor engagement.
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