Smartsheet · Smartsheet Privacy Policy · View original document ↗

Controller vs. Processor Bifurcation

High severity Unique · 0 of 325 platforms
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This analysis describes what Smartsheet'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 provision allocates responsibility for personal data governance by designating the customer as the entity responsible for establishing privacy policies and responding to data subject inquiries. The bifurcation clarifies that Smartsheet's primary obligation is to the customer organization, not to individual end-users whose data is processed through the platform.

Consumer impact (what this means for users)

Users whose data is collected through a customer's Smartsheet deployment operate under the customer organization's privacy policy rather than Smartsheet's policy directly. This provision establishes that data inquiries and privacy governance questions should be addressed to the customer organization, not to Smartsheet.

How other platforms handle this

LinkedIn Medium

If you are in the 'Designated Countries', LinkedIn Ireland Unlimited Company ('LinkedIn Ireland') will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services. If you are outside of the Designated Countries, LinkedIn Corporation will ...

Anthropic Medium

This Privacy Policy does not apply where Anthropic acts as a data processor and processes personal data on behalf of commercial customers using Anthropic's Commercial Services – for example, your employer has provisioned you a Claude for Work account, or you're using an app that is powered on the ba...

DocuSign Medium

When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certa...

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▸ View Original Clause Language DOCUMENT RECORD
"
When Smartsheet collects personal data on behalf of our customers (such as when a customer's employee or end-user uses the Smartsheet services), Smartsheet acts as a data processor and our customer acts as a data controller. In these cases, our customer's privacy policy governs the use of your personal data, and you should contact that customer if you have questions about how your personal data is used.

— Excerpt from Smartsheet's Smartsheet Privacy Policy

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
Smartsheet Privacy Policy
Entity
Smartsheet
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-005131
Document ID
CA-D-00712
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
aa3e2b37314e800adf6f92513bffd0a54c2369282b4a03c0788838ef681cf41e
Analysis generated
May 7, 2026 16:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Smartsheet
Document: Smartsheet Privacy Policy
Record ID: CA-P-005131
Captured: 2026-05-07 16:22:45 UTC
SHA-256: aa3e2b37314e800a…
URL: https://conductatlas.com/platform/smartsheet/smartsheet-privacy-policy/controller-vs-processor-bifurcation/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Smartsheet's Controller vs. Processor Bifurcation clause do?

This provision allocates responsibility for personal data governance by designating the customer as the entity responsible for establishing privacy policies and responding to data subject inquiries. The bifurcation clarifies that Smartsheet's primary obligation is to the customer organization, not to individual end-users whose data is processed through the platform.

How does this clause affect you?

Users whose data is collected through a customer's Smartsheet deployment operate under the customer organization's privacy policy rather than Smartsheet's policy directly. This provision establishes that data inquiries and privacy governance questions should be addressed to the customer organization, not to Smartsheet.

Is ConductAtlas affiliated with Smartsheet?

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