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The agreement incorporates LinkedIn's Data Processing Agreement and Standard Contractual Clauses for any processing of EU personal data under the agreement, and LinkedIn commits to updating the Standard Clauses as required by EU law. The incorporated DPA governs the controller and processor relationship between advertisers and LinkedIn for personal data processed through the Ad Services.
This analysis describes what LinkedIn'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 establishes the contractual framework for GDPR-compliant personal data transfers and processing through the LinkedIn Ad Services, incorporating the DPA and Standard Contractual Clauses by reference. The provision also states that LinkedIn will update the Standard Clauses as required by EU law, which is relevant for ongoing compliance with post-Schrems II transfer requirements.
Interpretive note: The specific version of the Standard Contractual Clauses and the full terms of the DPA are incorporated by reference from external documents not fully reproduced here; compliance assessment requires review of those documents.
Under this clause, advertisers processing EU personal data through the LinkedIn Ad Services are governed by the terms of LinkedIn's DPA and Standard Contractual Clauses, which are incorporated by reference into the Ads Agreement. The agreement states that advertisers act as controllers and LinkedIn acts as a processor for personal data disclosed to LinkedIn for processing on the advertiser's behalf.
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"If either party processes Personal Data (as defined in Section 1 of the LinkedIn Data Processing Agreement (the 'DPA') pursuant to this Ads Agreement, then we will each comply with the terms of the DPA, and, in addition, the LinkedIn Independent Controller Addendum, if applicable, to the Ad Services you use. Additionally, if and to the extent you do provide to LinkedIn any Personal Data in connection with the Ad Services, the sharing of which pursuant to the Agreement is regulated by the General Data Protection Regulation, you and LinkedIn will enter into and comply with the applicable Standard Contractual Clauses ('Standard Clauses'), the terms of which are incorporated by reference into this Agreement and which supersede any existing Standard Clauses in place between you and LinkedIn. LinkedIn agrees that (i) the Standard Clauses will be updated if required under European law or regulations, and (ii) your affiliates may enter into Standard Clauses directly with LinkedIn.Excerpt from LinkedIn's Ads Agreement
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR, specifically Chapter V provisions on international data transfers, and the European Data Protection Board guidance on Standard Contractual Clauses following the Schrems II judgment. EU supervisory authorities, including the Irish Data Protection Commission as LinkedIn's lead supervisory authority, are the primary enforcement bodies. The provision also engages the UK GDPR and ICO guidance on international transfers for UK-based advertisers. (2) GOVERNANCE EXPOSURE: Medium. The incorporation by reference of the DPA and Standard Contractual Clauses is standard practice for EU-facing advertising platforms; however, advertisers must confirm that the specific version of the Standard Clauses referenced by LinkedIn corresponds to the 2021 European Commission Standard Contractual Clauses and that any transfer impact assessments required under applicable guidance have been completed. (3) JURISDICTION FLAGS: EU and UK advertisers face the highest exposure under this provision and should confirm that the DPA and Standard Clauses are current and consistent with the applicable transfer mechanism in their member state. Swiss advertisers should assess whether LinkedIn's Standard Clauses are consistent with requirements under the Swiss Federal Act on Data Protection. (4) CONTRACT AND VENDOR IMPLICATIONS: Advertisers should review the full text of LinkedIn's DPA and Standard Contractual Clauses, available at the URLs referenced in the agreement, to confirm that the controller-processor role allocation is consistent with their GDPR compliance posture. Affiliates wishing to enter into Standard Clauses directly with LinkedIn should follow the procedure described in this provision. (5) COMPLIANCE CONSIDERATIONS: Data protection officers should confirm that the incorporated Standard Clauses are the current 2021 European Commission versions and that a transfer impact assessment has been completed if required. The DPA should be reviewed to confirm that technical and organizational security measures described therein are consistent with the advertiser's GDPR obligations as controller.
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This provision establishes the contractual framework for GDPR-compliant personal data transfers and processing through the LinkedIn Ad Services, incorporating the DPA and Standard Contractual Clauses by reference. The provision also states that LinkedIn will update the Standard Clauses as required by EU law, which is relevant for ongoing compliance with post-Schrems II transfer requirements.
Under this clause, advertisers processing EU personal data through the LinkedIn Ad Services are governed by the terms of LinkedIn's DPA and Standard Contractual Clauses, which are incorporated by reference into the Ads Agreement. The agreement states that advertisers act as controllers and LinkedIn acts as a processor for personal data disclosed to LinkedIn for processing on the advertiser's behalf.
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