Zoom contractually requires all listed subprocessors to meet obligations equivalent to those imposed on Zoom under its DPA, including instruction-based processing, personnel confidentiality obligations, breach notification to Zoom, and cooperation with data subject and regulatory requests.
This analysis describes what Zoom'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 provision establishes the contractual framework through which Zoom asserts downstream compliance obligations flow to its subprocessors; data controllers relying on this chain of obligations should verify whether Zoom's DPA explicitly grants controllers the right to audit or enforce against subprocessors directly or only through Zoom.
This provision establishes that subprocessors are contractually bound to process data only per customer instructions as communicated by Zoom, notify Zoom of breaches promptly, and cooperate on data subject requests. The agreement asserts these obligations flow through Zoom rather than directly from the data controller to the subprocessor.
Cross-platform context
See how other platforms handle Subprocessor Equivalence Obligations and similar clauses.
Compare across platforms →"Zoom requires its subprocessors to satisfy equivalent obligations as those required from Zoom (as a Data Processor) as outlined in Zoom's Data Processing Agreement (DPA), including but not limited to the requirements to: process personal data following data controller's (i.e., Customer's) instructions (as communicated to the relevant subprocessor by Zoom); in connection with the subprocessing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, under applicable data protection laws; promptly inform Zoom about any security breach; and cooperate with Zoom to address requests from data controllers, data subjects, or data protection authorities, as applicable.Excerpt from Zoom's Sub-Processors
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28(4), which requires that obligations imposed on processors are also imposed on subprocessors.
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This provision establishes the contractual framework through which Zoom asserts downstream compliance obligations flow to its subprocessors; data controllers relying on this chain of obligations should verify whether Zoom's DPA explicitly grants controllers the right to audit or enforce against subprocessors directly or only through Zoom.
This provision establishes that subprocessors are contractually bound to process data only per customer instructions as communicated by Zoom, notify Zoom of breaches promptly, and cooperate on data subject requests. The agreement asserts these obligations flow through Zoom rather than directly from the data controller to the subprocessor.
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