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
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.
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.
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"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
(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.
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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.
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.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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