Provision record
Twilio · Twilio Sub-Processors · View original document ↗

Sub-Processor Contractual Obligations and Technical Measures

Medium severity High confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The document states that Twilio requires all sub-processors to implement technical and organizational measures meeting applicable data protection law standards, enforced through written contracts between Twilio and each sub-processor.

This analysis describes what Twilio'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 establishes the contractual mechanism through which Twilio asserts downstream data protection obligations across its sub-processor network, forming the basis for GDPR Article 28 compliance assertions by Twilio customers who rely on Twilio's Data Protection Addendum.

Consumer impact (what this means for users)

The agreement states that personal data processed by sub-processors is subject to written contracts requiring data protection measures aligned with applicable law; Twilio customers relying on this provision should verify that the specific measures referenced align with their own regulatory obligations.

Cross-platform context

See how other platforms handle Sub-Processor Contractual Obligations and Technical Measures and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that the sub-processing of personal data is protected to the standards required by applicable data protection laws.

Excerpt from Twilio's Sub-Processors

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28, which requires that controllers use only processors providing sufficient guarantees regarding technical and organizational measures, and that processors engage sub-processors under equivalent binding obligations.

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 →

Provision details

Document information
Document
Twilio Sub-Processors
Entity
Twilio
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-015675
Document ID
CA-D-00933
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
eb0c920c72df0732ba3434b4acbc87ddf3cac2ad805f3e24639ec619d81bba39
Analysis generated
July 6, 2026 23:19 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Sub-Processors
Record ID: CA-P-015675
Captured: 2026-07-06 23:19:28 UTC
SHA-256: eb0c920c72df0732…
URL: https://conductatlas.com/platform/twilio/twilio-sub-processors/provision/CA-P-015675/sub-processor-contractual-obligations-and-technical-measures/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Twilio's Sub-Processor Contractual Obligations and Technical Measures clause do?

This provision establishes the contractual mechanism through which Twilio asserts downstream data protection obligations across its sub-processor network, forming the basis for GDPR Article 28 compliance assertions by Twilio customers who rely on Twilio's Data Protection Addendum.

How does this clause affect you?

The agreement states that personal data processed by sub-processors is subject to written contracts requiring data protection measures aligned with applicable law; Twilio customers relying on this provision should verify that the specific measures referenced align with their own regulatory obligations.

Is ConductAtlas affiliated with Twilio?

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