Monday.com · Monday.com Privacy Policy · View original document ↗

Controller vs. Processor Distinction

Medium severity High confidence Explicitdocumentlanguage Rare · 1 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for Monday.com Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

Monday.com acts as a data processor for content your employer or team uploads to the platform, meaning your employer's privacy policy governs that data, not monday.com's. Monday.com is only the controller for its own marketing and operational data.

This analysis describes what Monday.com'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 distinction means individual employees using monday.com through a corporate account should look to their employer's privacy policy for rights over their work data, as monday.com does not act as the controller and this policy does not grant rights over that data category.

Consumer impact (what this means for users)

If you use monday.com through your employer, your work-related personal data is controlled by your employer, not monday.com, which limits the rights you can exercise directly against monday.com for that data and shifts the privacy accountability to your organization.

How other platforms handle this

Auth0 Medium

When Okta provides its products and services to its customers (e.g., organizations that use Okta to manage their workforce or Auth0 to manage their customer identity), Okta processes personal data on behalf of those customers as a data processor. In those cases, the customer is the data controller a...

Smartsheet Medium

When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...

DocuSign Medium

Docusign may be a 'data controller' or a 'data processor' (or both) depending on the type of personal information and the context in which it is processed. When Docusign determines the purpose and means of processing personal information, we act as a data controller. When Docusign processes personal...

See all platforms with this clause type →

Monitoring

Monday.com has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
In providing our services to our customers, we act as a data processor on behalf of our customers who are data controllers. Our customers' privacy policies govern their use of the monday.com platform. For information about the personal data our customers process using the monday.com platform, please refer to the relevant customer's privacy policy. When we process personal data for our own purposes (for example, to manage our relationship with customers, for marketing, or to improve our services), we act as a data controller.

— Excerpt from Monday.com's Monday.com Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision is structurally significant under GDPR Articles 4(7) and 4(8) (controller and processor definitions) and Article 28 (processor obligations). The allocation of controller and processor roles determines which entity bears primary accountability to data subjects and regulators. If this allocation is inaccurate (e.g., if monday.com makes independent decisions about customer data beyond mere processing), supervisory authorities may determine monday.com is a joint controller, creating additional liability. (2) GOVERNANCE EXPOSURE: High for enterprise customers. The processor designation means the rights of individual users (employees) must be honored by the controller customer organization, not monday.com. This shifts the DSAR response obligation to the employer, but requires the employer to have contractual mechanisms in place to obtain data from monday.com to fulfill those requests. Failure to have an adequate DPA in place with monday.com creates a compliance gap. (3) JURISDICTION FLAGS: GDPR-regulated organizations must have a signed DPA with monday.com meeting Article 28 requirements before processing personal data. UK GDPR imposes equivalent requirements. California organizations should consider whether monday.com's processor role is consistent with a 'service provider' relationship under CPRA, which requires specific contractual restrictions on monday.com's use of data. (4) CONTRACT AND VENDOR IMPLICATIONS: The DPA is the critical document for this provision. Procurement and legal teams must confirm the DPA is executed, current, and includes audit rights, sub-processor notification obligations, and data return or deletion procedures upon contract termination. The DPA should specify that monday.com does not use customer data for its own commercial purposes, including advertising, in the processor capacity. (5) COMPLIANCE CONSIDERATIONS: Organizations should ensure their internal privacy notices to employees disclose that monday.com processes personal data as a processor on the organization's behalf, and that the organization is the controller responsible for honoring employee data rights. DSAR procedures should include a step for obtaining responsive data from monday.com via the DPA's data subject request assistance mechanism.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has authority over deceptive privacy representations, including whether the controller/processor allocation accurately reflects the operational reality of monday.com's data handling practices.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Monday.com Privacy Policy
Entity
Monday.com
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-008741
Document ID
CA-D-00554
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
cc7438a0a1190b919e18920b4392c76cbd5a30ebf48756d7000dfa42159e6e7a
Analysis generated
May 7, 2026 23:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Monday.com
Document: Monday.com Privacy Policy
Record ID: CA-P-008741
Captured: 2026-05-07 23:01:40 UTC
SHA-256: cc7438a0a1190b91…
URL: https://conductatlas.com/platform/mondaycom/mondaycom-privacy-policy/controller-vs-processor-distinction/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Monday.com's Controller vs. Processor Distinction clause do?

This distinction means individual employees using monday.com through a corporate account should look to their employer's privacy policy for rights over their work data, as monday.com does not act as the controller and this policy does not grant rights over that data category.

How does this clause affect you?

If you use monday.com through your employer, your work-related personal data is controlled by your employer, not monday.com, which limits the rights you can exercise directly against monday.com for that data and shifts the privacy accountability to your organization.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with Monday.com?

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