ZipRecruiter · ZipRecruiter Privacy Policy · View original document ↗

Dual Controller-Processor Role

Medium severity Rare · 1 of 325 platforms
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This analysis describes what ZipRecruiter'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 clause delineates ZipRecruiter's operational role in data processing arrangements where clients retain primary control over personal data. This allocation affects the routing of data subject rights requests and establishes that ZipRecruiter's responsibility is limited to processing under client direction rather than independent data stewardship.

Consumer impact (what this means for users)

Where ZipRecruiter operates as a processor, individuals seeking to exercise data rights must contact the data controller (the hiring client) directly rather than ZipRecruiter. The provision requires ZipRecruiter to supply the data controller's contact information to facilitate this directed communication.

How other platforms handle this

Amplitude Medium

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...

Microsoft Azure Medium

When we provide enterprise online services to an organization that has licensed these services from Microsoft, we act as a data processor for the organization, which is the data controller. In these cases, the organization determines the personal data Microsoft collects on its behalf and how that da...

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...

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▸ View Original Clause Language DOCUMENT RECORD
"
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 (data subjects) whose Personal Data we process. 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, or have other request, we will provide you with the data controller's contact information, so you can contact them directly.

— Excerpt from ZipRecruiter's ZipRecruiter Privacy Policy

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
ZipRecruiter Privacy Policy
Entity
ZipRecruiter
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-005494
Document ID
CA-D-00292
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
dc46eccd019602b8c465ad39b57e8786dee66b3142e75575f344c37dbe55372d
Analysis generated
May 7, 2026 20:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: ZipRecruiter
Document: ZipRecruiter Privacy Policy
Record ID: CA-P-005494
Captured: 2026-05-07 20:51:33 UTC
SHA-256: dc46eccd019602b8…
URL: https://conductatlas.com/platform/ziprecruiter/ziprecruiter-privacy-policy/dual-controller-processor-role/
Accessed: May 20, 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 ZipRecruiter's Dual Controller-Processor Role clause do?

The clause delineates ZipRecruiter's operational role in data processing arrangements where clients retain primary control over personal data. This allocation affects the routing of data subject rights requests and establishes that ZipRecruiter's responsibility is limited to processing under client direction rather than independent data stewardship.

How does this clause affect you?

Where ZipRecruiter operates as a processor, individuals seeking to exercise data rights must contact the data controller (the hiring client) directly rather than ZipRecruiter. The provision requires ZipRecruiter to supply the data controller's contact information to facilitate this directed communication.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with ZipRecruiter?

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