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Atlassian sub-processors questions

marc -Collabello--Phase Locked-

Atlassian has published a list of sub-processors here: https://www.atlassian.com/legal/sub-processors .

However this list of sub-processors seems not complete. When you use Conflucence, Jira, and other Atlassian sites, data gets transferred to (among others):

Google (Google fonts, Analytics, Ads)
Launchdarkly
Linkedin
Facebook
Clicktale
Vimeo
Optimizely
Marketo
Reddit
Doubleclick
Bing

Actually the site listing the sub-processors uses all of the above as of today (Monday, November 21, 2022).

Comments

Nic Brough -Adaptavist-

I would point out that a lot of those are probably being called by apps, not the core Atlassian systems.

Dave Meyer

Our cloud infrastructure and architecture for our products is distinct from www.atlassian.com. The presence of references to these services on a www.atlassian.com page does not mean that they are present in Jira, Confluence, or our other products.

Additionally, the definition of a sub-processor in the GDPR specifically refers to access to data. The presence of a cookie or 3rd-party library does not imply that a vendor is a sub-processor.

marc -Collabello--Phase Locked-

@Nic Brough -Adaptavist- These services are on the atlassian.com domain, and are not caused by apps.

@Dave Meyer Atlassian.com is required for e.g. login, documentation and the marketplace. So in effect I would say it is "part of" the Jira and Confluence offer.

Once you install cookies or 3rd party libraries on a website, the vendors (or providers) are sub-processors in terms of GDPR. See for example the explanation at https://www.simpleanalytics.com/blog/denmark-declares-google-analytics-unlawful which references the original letter of the Danish DPA.

marc -Collabello--Phase Locked-

@Dave Meyer , @Nic Brough -Adaptavist- ,

I have found a link where Atlassian says it is using specific external services: https://support.atlassian.com/organization-administration/docs/ip-addresses-and-domains-for-atlassian-cloud-products/

Among these are:

Pubnub
Wordpress/Gravatar Content Delivery Network
Google Hosted Libraries Content Delivery Network
Optimizely Digital Experience delivery
LaunchDarkly Digital Experience delivery
Twilio Segment
Sentry.io Content Delivery Network

These external services must be declared as subprocessors, if Atlassian uses them in their applications.

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