Provision record
Workday · Workday Privacy Statement · View original document ↗

Dual Controller and Processor Role

Medium severity Medium confidence Inferred from context Common · 289 of 352 platforms
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Document Record

What it is

Workday acts in two distinct roles: as a data controller when collecting your information through its own website and marketing, and as a data processor handling employee data on behalf of your employer. Which role applies determines where you must go to exercise your privacy rights.

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)

If you are an employee using Workday at work, your employer, not Workday, is typically the controller of your HR data, which means you may need to direct privacy requests to your employer rather than to Workday directly.

Interpretive note: The document was truncated before operative clauses were visible; the controller-processor distinction is inferred from Workday's known business model and the statement's general framing rather than from explicit document language.

Clause Stability Stable

0
Changes
4
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

This structural distinction affects where employees must go to access, correct, or delete their personal data. Employees whose HR data is processed through Workday may find that Workday is not the right contact for exercising their data rights, as those rights must be addressed through the employer who controls the data.

How other platforms handle this

ZipRecruiter Medium

Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Skillshare Medium

When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
At Workday, we believe privacy is a fundamental right, regardless of where you live. When you connect with Workday, we understand you are trusting us to handle your personal information appropriately. That is why we are committed to transparency about how we collect, use, and share that information.

Excerpt from Workday's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: GDPR Articles 4, 24, and 28 establish distinct obligations for controllers and processors.

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 →

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
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-009563
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-009563
Captured: 2026-05-08 08:59:38 UTC
SHA-256: 1d1c8751f74511b4…
URL: https://conductatlas.com/platform/workday/workday-privacy-statement/provision/CA-P-009563/dual-controller-and-processor-role/
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 Workday's Dual Controller and Processor Role clause do?

If you are an employee using Workday at work, your employer, not Workday, is typically the controller of your HR data, which means you may need to direct privacy requests to your employer rather than to Workday directly.

How does this clause affect you?

This structural distinction affects where employees must go to access, correct, or delete their personal data. Employees whose HR data is processed through Workday may find that Workday is not the right contact for exercising their data rights, as those rights must be addressed through the employer who controls the data.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 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.