Plaid · Plaid End User Privacy Policy · View original document ↗

IDV Plaid as data processor not controller

High severity High confidence Explicitdocumentlanguage Common · 280 of 352 platforms
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This analysis describes what Plaid'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)

The data controller designation rests with Plaid's customers, not with Plaid, which affects who bears primary legal responsibility for processing decisions and to whom users may need to direct certain rights requests.

Interpretive note: The evidence span contains an ellipsis indicating text was omitted from the excerpt; there may be additional conditions or qualifications in the full clause.

Recent Activity

This document changed recently

High Apr 21, 2026

End consumers may see their financial data accessed by a broader range of people under developer accounts, but Plaid now requires developers to formally designate and manage these 'Authorized Users' and take responsibility for their conduct. The introduction of session replay and activity monitoring means developer interactions with your financial data may be recorded for audit or security purposes. The policy does not specify what data is covered by monitoring or how long recordings are retained, which creates operational uncertainty for developers handling sensitive consumer financial information.

View change record →
Medium Apr 19, 2026

Plaid's updated terms establish a new direct relationship with you through the Plaid Account and introduce a monitoring service that operates through a web app. The terms now authorize Plaid to share financial information needed for third-party apps to initiate payments to or from you, which is a broader statement of data-sharing scope than the previous language. This means Plaid's role shifts from primarily facilitating connections to third-party apps toward directly providing account services, including monitoring. The effective date is April 14, 2026, though the change was detected on April 19, 2026. Review your Plaid Account settings to understand what data Plaid holds and how the monitoring service works.

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Medium Apr 3, 2026

The updated terms clarify that Plaid may request and collect phone numbers, email addresses, and other contact information when you connect financial accounts or verify your identity through a Plaid-connected application. The terms no longer describe a separate Plaid Monitoring Service or Plaid Web-App. The Plaid Account is now framed primarily as a tool to accelerate onboarding and use of third-party applications rather than as a standalone service for monitoring and alerts. The updated language authorizes Plaid to store identity verification data within your Plaid Account if you choose to do so.

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Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 3354 other provisions on other platforms.

Consumer impact (what this means for users)

When Plaid processes your personal information for IDV Services, the purpose and means of that processing are controlled by Plaid's customer, not by Plaid itself.

How other platforms handle this

ZipRecruiter Medium

In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals...

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

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Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
When we provide IDV Services to our Customers, our Customers determine the purpose and means by which Personal Information is processed... Plaid is a data processor or sub-processor when it facilitates identity verification...

— Excerpt from Plaid's Plaid End User Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal

Provision details

Document information
Document
Plaid End User Privacy Policy
Entity
Plaid
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-028795
Document ID
CA-D-00169
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0a8d827572962cc5012319c796e08d8fb49190be40484061ff10c08cf6718f4b
Analysis generated
May 9, 2026 15:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Plaid
Document: Plaid End User Privacy Policy
Record ID: CA-P-028795
Captured: 2026-05-09 15:51:01 UTC
SHA-256: 0a8d827572962cc5…
URL: https://conductatlas.com/platform/plaid/plaid-end-user-privacy-policy/provision/CA-P-028795/idv-plaid-as-data-processor-not-controller/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Plaid's IDV Plaid as data processor not controller clause do?

The data controller designation rests with Plaid's customers, not with Plaid, which affects who bears primary legal responsibility for processing decisions and to whom users may need to direct certain rights requests.

How does this clause affect you?

When Plaid processes your personal information for IDV Services, the purpose and means of that processing are controlled by Plaid's customer, not by Plaid itself.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.

Is ConductAtlas affiliated with Plaid?

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