Provision record
Smartsheet · Smartsheet Privacy Policy · View original document ↗

Controller vs. Processor Distinction for Service Data

Medium severity High confidence Explicit document language Common · 290 of 352 platforms
Stay ahead of the changes
Track Smartsheet and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

If you use Smartsheet because your employer or another organization set it up, that organization controls your data inside the platform, not Smartsheet. Your privacy rights for that data must be directed to your employer, not Smartsheet.

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)

Many employees who use Smartsheet at work assume they can ask Smartsheet to delete or access their data, but this clause means Smartsheet may redirect those requests to the employer, potentially limiting practical privacy recourse.

Recent Activity

This document changed recently

Medium Jun 5, 2026

The updated privacy policy states that only Smartsheet's U.S.-based affiliates participate in the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework. Previously, the policy referenced participation by Smartsheet and its affiliates without geographic qualification. This narrowed scope may affect the data transfer mechanisms available for processing personal data from EU, UK, and Swiss users if non-U.S. affiliates are involved in data handling. The policy does not explicitly describe alternative transfer mechanisms for non-U.S. affiliates.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Individual employees using Smartsheet through a workplace account may not be able to exercise GDPR or CCPA rights directly with Smartsheet for data submitted into the platform; they must contact their employer instead, which could complicate or delay privacy right fulfillment.

How other platforms handle this

ZipRecruiter Medium

Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.

Google Cloud Medium

You and your organization's administrator can access several types of Service Data directly from Google Cloud, including your account information, billing contact information, payment and transaction information, as well as product and communication settings and configurations.

Square Medium

to request that your data be transferred to a third party (data portability)

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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 customer's implementation of the Service and you have questions about how your personal data is processed in that context, please contact the relevant customer directly.

Excerpt from Smartsheet's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28, which requires a written Data Processing Agreement between controller and processor, and CCPA service provider designation requirements.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

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-008057
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-008057
Captured: 2026-05-07 16:22:45 UTC
SHA-256: aa3e2b37314e800a…
URL: https://conductatlas.com/platform/smartsheet/smartsheet-privacy-policy/provision/CA-P-008057/controller-vs-processor-distinction-for-service-data/
Accessed: Aug. 11, 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

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Smartsheet's Controller vs. Processor Distinction for Service Data clause do?

Many employees who use Smartsheet at work assume they can ask Smartsheet to delete or access their data, but this clause means Smartsheet may redirect those requests to the employer, potentially limiting practical privacy recourse.

How does this clause affect you?

Individual employees using Smartsheet through a workplace account may not be able to exercise GDPR or CCPA rights directly with Smartsheet for data submitted into the platform; they must contact their employer instead, which could complicate or delay privacy right fulfillment.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Smartsheet?

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