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Atlassian sub-processors questions

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).

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Nic Brough -Adaptavist-
Community Leader
Community Leader
Community Leaders are connectors, ambassadors, and mentors. On the online community, they serve as thought leaders, product experts, and moderators.
November 21, 2022

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

Dave Meyer
Atlassian Team
Atlassian Team members are employees working across the company in a wide variety of roles.
November 21, 2022

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-
Community Leader
Community Leader
Community Leaders are connectors, ambassadors, and mentors. On the online community, they serve as thought leaders, product experts, and moderators.
November 22, 2022

@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.

Like Steffen Opel _Utoolity_ likes this
marc -Collabello--Phase Locked-
Community Leader
Community Leader
Community Leaders are connectors, ambassadors, and mentors. On the online community, they serve as thought leaders, product experts, and moderators.
February 3, 2023

@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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