The document states that telecommunications providers used by Twilio in the provision of its services are not classified as processors of Twilio or sub-processors of Twilio's customers, distinguishing them from the entities listed in the sub-processor table.
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
This exclusion means that personal data transmitted through telecommunications providers used by Twilio is not covered by the sub-processor contractual obligations, Transfer Impact Assessments, or technical and organizational measure requirements described elsewhere in the document, which may create a gap in the data protection chain for communications-related processing.
Interpretive note: Twilio's characterization of telecommunications providers as non-processors is a legal position that may require evaluation against GDPR and UK GDPR definitions and applicable regulatory guidance; the referenced additional information is not included in the provided document text.
The document states that telecommunications providers used by Twilio fall outside the sub-processor framework and the associated contractual data protection obligations; customers should assess what data protection obligations, if any, apply to personal data transmitted through those providers and whether that gap is addressed in their DPA with Twilio.
Cross-platform context
See how other platforms handle Telecommunications Providers Excluded from Sub-Processor Classification and similar clauses.
Compare across platforms →"Please note that telecommunications providers used by Twilio are not processors of Twilio or sub-processors of our customers. Additional information about this position can be found here.Excerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR definitions of 'processor' and 'sub-processor' under Article 4 and Article 28, and the question of whether telecommunications providers that transmit personal data on behalf of Twilio fall within …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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.
This exclusion means that personal data transmitted through telecommunications providers used by Twilio is not covered by the sub-processor contractual obligations, Transfer Impact Assessments, or technical and organizational measure requirements described elsewhere in the document, which may create a gap in the data protection chain for communications-related processing.
The document states that telecommunications providers used by Twilio fall outside the sub-processor framework and the associated contractual data protection obligations; customers should assess what data protection obligations, if any, apply to personal data transmitted through those providers and whether that gap is addressed in their DPA with Twilio.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.