Workday · Workday Privacy Statement · View original document ↗

Workday acts as processor for employer-controlled data

High severity High confidence Explicitdocumentlanguage Common · 280 of 352 platforms
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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)

The controller/processor distinction determines who bears primary legal responsibility for data protection decisions and to whom individuals must direct rights requests.

Consumer impact (what this means for users)

If your employer provides your access to Workday, your employer—not Workday—is the legal controller of your personal information, and Workday processes that data only on your employer's behalf.

How other platforms handle this

ZipRecruiter Medium

In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals...

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

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▸ View Original Clause Language DOCUMENT RECORD
"
When you use a Workday enterprise cloud application provided by your employer or another organization, that organization is the controller of your personal information. In these cases, Workday acts as a processor on their behalf.

— 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-051480
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-051480
Captured: 2026-05-08 08:59:38 UTC
SHA-256: 1d1c8751f74511b4…
URL: https://conductatlas.com/platform/workday/workday-privacy-statement/provision/CA-P-051480/workday-acts-as-processor-for-employer-controlled-data/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Workday's Workday acts as processor for employer-controlled data clause do?

The controller/processor distinction determines who bears primary legal responsibility for data protection decisions and to whom individuals must direct rights requests.

How does this clause affect you?

If your employer provides your access to Workday, your employer—not Workday—is the legal controller of your personal information, and Workday processes that data only on your employer's behalf.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 280 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.