Workday · Workday Privacy Statement · View original document ↗

Controller vs. Processor Dual Role

High severity Rare · 2 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for Workday Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.

This analysis describes what Workday'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 clause delineates Workday's operational role and responsibility boundaries in the data processing relationship. By identifying the business customer as the data controller, the provision clarifies that the customer organization—not Workday—bears primary responsibility for determining the lawful basis and purposes of personal data processing.

Consumer impact (what this means for users)

Under this provision, individuals whose data is processed through Workday services should direct data-related inquiries and requests to their employer or business customer rather than to Workday, since the employer controls how personal information is processed. This establishes the procedural pathway for individual data subjects to assert privacy rights through their organization's data controller.

How other platforms handle this

Smartsheet Medium

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 custome...

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...

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 ...

See all platforms with this clause type →

Monitoring

Workday has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
When Workday provides its services to business customers (e.g., employers), Workday processes personal information on behalf of those customers and is acting as a data processor. In that context, the business customer is the data controller and is responsible for determining how personal information is processed. If you are an employee, job applicant, or contractor of a Workday customer and you have questions about how your data is processed, please contact that Workday customer directly.

— Excerpt from Workday's Workday Privacy Statement

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal

Provision details

Document information
Document
Workday Privacy Statement
Entity
Workday
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-006306
Document ID
CA-D-00643
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1d1c8751f74511b4904051a1bdb007f27fb1c00c83b0a76e5a3f374aa1db5246
Analysis generated
May 8, 2026 08:59 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Workday
Document: Workday Privacy Statement
Record ID: CA-P-006306
Captured: 2026-05-08 08:59:38 UTC
SHA-256: 1d1c8751f74511b4…
URL: https://conductatlas.com/platform/workday/workday-privacy-statement/controller-vs-processor-dual-role/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Workday's Controller vs. Processor Dual Role clause do?

This clause delineates Workday's operational role and responsibility boundaries in the data processing relationship. By identifying the business customer as the data controller, the provision clarifies that the customer organization—not Workday—bears primary responsibility for determining the lawful basis and purposes of personal data processing.

How does this clause affect you?

Under this provision, individuals whose data is processed through Workday services should direct data-related inquiries and requests to their employer or business customer rather than to Workday, since the employer controls how personal information is processed. This establishes the procedural pathway for individual data subjects to assert privacy rights through their organization's data controller.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.

Is ConductAtlas affiliated with Workday?

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