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
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.
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
Mixpanel acts as a data processor on behalf of its customers (the controllers) when processing end user data through the Mixpanel analytics platform, and as a data controller with respect to data it collects about its own website visitors and account holders.
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...
Amplitude acts as a data controller when we collect and use Personal Information for our own purposes, such as providing and improving our Services, marketing, and other business operations. When Amplitude processes Personal Information on behalf of our customers (for example, event data that our cu...
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"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
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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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.
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.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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