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
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.
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
When Zendesk processes personal data on behalf of its customers, Zendesk acts as a data processor and the customer acts as the data controller. In those cases, the customer's privacy policy and data processing agreement with Zendesk govern the processing of that data, not this Privacy Notice. If you...
When Okta provides its products and services to its customers (e.g., organizations that use Okta to manage their workforce or Auth0 to manage their customer identity), Okta processes personal data on behalf of those customers as a data processor. In those cases, the customer is the data controller a...
Docusign may be a 'data controller' or a 'data processor' (or both) depending on the type of personal information and the context in which it is processed. When Docusign determines the purpose and means of processing personal information, we act as a data controller. When Docusign processes personal...
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"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 Smartsheet Privacy Policy
(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. The relevant enforcement authorities are data protection authorities in EU member states and the UK ICO for GDPR, and the California Attorney General and California Privacy Protection Agency for CCPA. Where enterprise customers have not executed a compliant DPA with Smartsheet, they may face regulatory exposure as controllers. (2) GOVERNANCE EXPOSURE: High. Enterprise customers who deploy Smartsheet must ensure a GDPR-compliant DPA is in place. Failure to do so could result in enforcement action against the customer organization as controller. The provision also affects data subject rights response workflows, as Smartsheet asserts it will not fulfill end-user rights requests for processor data. (3) JURISDICTION FLAGS: EU, EEA, and UK organizations face the highest exposure given GDPR's mandatory DPA requirements. California-based organizations must ensure Smartsheet is designated as a service provider under CCPA to restrict onward data use. Organizations in other jurisdictions with omnibus privacy laws (e.g., Brazil LGPD, Canada PIPEDA) should evaluate whether equivalent processor agreement requirements apply. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm a Smartsheet DPA is executed before deploying the service for any processing of personal data subject to GDPR or CCPA. The provision asserts that individual end-user rights requests for service data will be redirected to the customer, which aligns with standard processor practice but requires customers to have an operational process for receiving and responding to such requests. (5) COMPLIANCE CONSIDERATIONS: Enterprise compliance teams should map which categories of personal data are submitted into Smartsheet sheets, confirm DPA coverage, and establish internal procedures for handling data subject rights requests that Smartsheet redirects to them. Organizations in regulated sectors should assess whether sector-specific data handling obligations (e.g., HIPAA, FERPA) are addressed in supplemental agreements with Smartsheet.
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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.
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.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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