Provision record
Zoom · Zoom Sub-Processors · View original document ↗

Subprocessors must follow customer data controller instructions

High severity High confidence Explicit document language Common · 279 of 352 platforms

Key Facts

Does Zoom require its subprocessors to process personal data following the data controller's instructions?
Zoom requires its subprocessors to process personal data following the data controller's (i.e., the Customer's) instructions, as communicated to the relevant subprocessor by Zoom.
How are the data controller's instructions communicated to the relevant subprocessor?
Zoom requires its subprocessors to process personal data following the data controller's (i.e., the Customer's) instructions, as communicated to the relevant subprocessor by Zoom.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Subprocessors are contractually required to follow Customer instructions as relayed by Zoom, meaning Zoom acts as the conduit for Customer control over how personal data is processed.

Consumer impact (what this means for users)

Zoom's subprocessors must process your personal data only according to your instructions as a Customer, communicated through Zoom.

How other platforms handle this

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.

Square Medium

we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
process personal data following data controller's (i.e., Customer's) instructions (as communicated to the relevant subprocessor by Zoom)

Excerpt from Zoom's Sub-Processors

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Zoom Sub-Processors
Entity
Zoom
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-067051
Document ID
CA-D-00930
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
144798ca3a98501441f47060f315ea5ef2278a02e7cf3920b5f7e32307047e01
Analysis generated
July 6, 2026 23:07 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Zoom
Document: Zoom Sub-Processors
Record ID: CA-P-067051
Captured: 2026-07-06 23:07:54 UTC
SHA-256: 144798ca3a985014…
URL: https://conductatlas.com/platform/zoom/zoom-sub-processors/provision/CA-P-067051/subprocessors-must-follow-customer-data-controller-instructions/
Accessed: Aug. 18, 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 Zoom's Subprocessors must follow customer data controller instructions clause do?

Subprocessors are contractually required to follow Customer instructions as relayed by Zoom, meaning Zoom acts as the conduit for Customer control over how personal data is processed.

How does this clause affect you?

Zoom's subprocessors must process your personal data only according to your instructions as a Customer, communicated through Zoom.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.

Is ConductAtlas affiliated with Zoom?

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