Notion provides a Data Processing Addendum (DPA) and publishes a list of third-party sub-processors for enterprise customers who need GDPR-compliant data processing arrangements.
This analysis describes what Notion'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
EU/EEA organizations and any organization processing EU personal data through Notion must have a valid DPA in place under GDPR; the existence of a published Sub-processors list enables customers to assess third-party data sharing and object to new sub-processors.
Interpretive note: The specific terms of the DPA including audit rights, breach notification timelines, and cross-border transfer mechanisms cannot be assessed from this index page and require review of the full DPA document.
Enterprise customers in the EU or those processing EU personal data can execute Notion's DPA to establish a GDPR-compliant processing relationship; individual consumers benefit indirectly from the sub-processor transparency this framework provides.
How other platforms handle this
Miro's processing of personal data on behalf of customers is governed by the Customer Data Processing Addendum, which is incorporated into these Terms by reference. A current list of subprocessors used by Miro is available at miro.com/legal/subprocessors-list/ and is updated from time to time.
We may access, preserve, and share information with regulators, law enforcement, or others if we believe it is reasonably necessary to: detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others, including as part of investigations; and prevent death or imminen...
Customer authorized Mistral AI to transfer Personal Data to any country deemed to have an adequate level of data protection by the European Commission. Customer also authorizes Mistral AI to perform International Data Transfers to (a) on the basis of adequate safeguards in accordance with Applicable...
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"Data Processing Addendum | Sub-processors— Excerpt from Notion's Notion Terms of Service
REGULATORY LANDSCAPE: The DPA directly implicates GDPR Article 28, which mandates written contracts between data controllers and processors. The Sub-processors list is relevant to GDPR Article 28(2), which requires processors to obtain controller authorization before engaging sub-processors. UK GDPR imposes equivalent requirements for UK-based organizations. GOVERNANCE EXPOSURE: Medium. The provision of a DPA is a positive compliance signal, but the adequacy of that DPA's specific terms (security obligations, audit rights, breach notification timelines, data return or deletion upon termination) requires individual review. JURISDICTION FLAGS: EU/EEA and UK organizations face mandatory DPA requirements; organizations in Switzerland face Swiss DPA requirements. US organizations in regulated industries such as healthcare or financial services may also need DPA-equivalent provisions for their own compliance frameworks. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should execute the DPA before processing any personal data in Notion at an organizational level. The Sub-processors list should be reviewed against internal vendor approval processes, and teams should confirm whether Notion's DPA includes notification rights when sub-processors change. COMPLIANCE CONSIDERATIONS: Legal teams should verify the DPA includes adequate provisions for data subject rights fulfillment, cross-border transfer mechanisms (Standard Contractual Clauses or equivalent), security obligations, and audit rights. The Sub-processors list should be incorporated into the organization's data mapping documentation.
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EU/EEA organizations and any organization processing EU personal data through Notion must have a valid DPA in place under GDPR; the existence of a published Sub-processors list enables customers to assess third-party data sharing and object to new sub-processors.
Enterprise customers in the EU or those processing EU personal data can execute Notion's DPA to establish a GDPR-compliant processing relationship; individual consumers benefit indirectly from the sub-processor transparency this framework provides.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Notion.