Provision record
Greenhouse · Greenhouse Privacy Policy · View original document ↗

Processor vs. Controller Scope Distinction

Medium severity High confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

This policy explicitly excludes from its scope the Personal Information that Greenhouse processes as a processor on behalf of enterprise customers, including job applicant data submitted through customer-hosted career pages; such data is governed by the respective customer's privacy policy.

This analysis describes what Greenhouse'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 provision establishes that individuals who apply for jobs through Greenhouse-powered career pages of third-party employers have no direct data rights relationship with Greenhouse under this policy and must contact the employer directly for data access, correction, or deletion requests.

Consumer impact (what this means for users)

This provision establishes that Greenhouse will redirect data subject requests related to customer-processed recruiting data back to the employing organization without taking action. Job applicants whose data is processed by Greenhouse on behalf of an employer must contact that employer directly to exercise data rights.

Cross-platform context

See how other platforms handle Processor vs. Controller Scope Distinction and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Greenhouse is a leading provider of cloud-based software services that help companies manage and optimize their recruiting and hiring processes. Greenhouse processes personal data in the following contexts: 1. As a processor on behalf of its customers for recruiting and onboarding purposes. This Privacy Policy does not apply to Personal Information in this context. Our customers are the controllers of the Personal Information they collect through Greenhouse's Services to manage their own recruiting and onboarding processes (e.g., names, contact information, and other data collected as part of job applications), and each customer manages that Personal Information in accordance with its own privacy policies. Greenhouse's customer contracts require us to redirect inquiries relating to the Personal Information we process on behalf of a customer back to that customer without taking any action on the request.

Excerpt from Greenhouse's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Greenhouse Privacy Policy
Entity
Greenhouse
Document last updated
July 5, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-015548
Document ID
CA-D-00918
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8eed11ab4b13cf36349d959508396725d190ee2515f43b08f6e7be1f429e377d
Analysis generated
July 6, 2026 15:44 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Greenhouse
Document: Greenhouse Privacy Policy
Record ID: CA-P-015548
Captured: 2026-07-06 15:44:37 UTC
SHA-256: 8eed11ab4b13cf36…
URL: https://conductatlas.com/platform/greenhouse/greenhouse-privacy-policy/provision/CA-P-015548/processor-vs-controller-scope-distinction/
Accessed: Sept. 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 Greenhouse's Processor vs. Controller Scope Distinction clause do?

This provision establishes that individuals who apply for jobs through Greenhouse-powered career pages of third-party employers have no direct data rights relationship with Greenhouse under this policy and must contact the employer directly for data access, correction, or deletion requests.

How does this clause affect you?

This provision establishes that Greenhouse will redirect data subject requests related to customer-processed recruiting data back to the employing organization without taking action. Job applicants whose data is processed by Greenhouse on behalf of an employer must contact that employer directly to exercise data rights.

Is ConductAtlas affiliated with Greenhouse?

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