Qualtrics: DPA, subprocessors and transfers

Links last opened 4 October 2026. Record confirmed by a person on 3 October 2026. 1 recorded change, listed below.

Qualtrics contracts through Qualtrics LLC, registered in United States. Transfers of personal data out of the EEA are covered by EU-US Data Privacy Framework (DPF). Its customer data processing agreement, also called a data processing addendum, is published by Qualtrics itself; the link is below. Its sub-processor list is published by Qualtrics itself; the link is below. We open those pages every day — last on 4 October 2026 — and a person last went through this record on 3 October 2026.

Contracting legal entity: Qualtrics LLC
Country of registration: United States
Transfer mechanism: EU-US Data Privacy Framework (DPF)
A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope.
Data processing agreement: https://www.qualtrics.com/scc-update/
Subprocessor list: https://www.qualtrics.com/subprocessor-list/
Security or trust page: We read Qualtrics's own site on 6 October 2026 and found none there. It may exist behind a login or on request — this says what a visitor can reach, not what the company has.

What to put in your subprocessor list

A ready row. Replace the purpose with what your client actually uses Qualtrics for.

Subprocessor	Legal entity	Country	Purpose	Transfer	DPA
Qualtrics	Qualtrics LLC	US	Analytics	DPF	https://www.qualtrics.com/scc-update/

Questions people ask about Qualtrics

Where is Qualtrics's DPA?: Qualtrics publishes its customer data processing agreement at https://www.qualtrics.com/scc-update/. We last opened that link on 4 October 2026.
Is Qualtrics's DPA the same thing as a data processing addendum?: Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Qualtrics's is at https://www.qualtrics.com/scc-update/.
Where is Qualtrics's sub-processor list?: Qualtrics publishes the list of its own sub-processors at https://www.qualtrics.com/subprocessor-list/. We last opened that link on 4 October 2026.
Which legal entity does Qualtrics contract through?: Qualtrics LLC, registered in United States. That is the name to put in a record of processing or a sub-processor list, not the brand.
What covers a transfer of personal data to Qualtrics outside the EEA?: EU-US Data Privacy Framework (DPF). A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope. Whether that is enough for a particular processing operation is a judgement for the controller.

What has changed, and when

Changes we noticed on Qualtrics's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

4 October 2026
We recorded changes to the transfer mechanism, the UK transfer mechanism.

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Worked out from the registry and what we have written: the country this vendor contracts from, the guides that answer the question this page raises, and the rest of the registry.

Other analytics

Six of them. All analytics in the registry · others that transfer the same way.

Subprocessor

Legal entity

Country

Purpose

Transfer

DPA

Qualtrics

Qualtrics LLC

Analytics

DPF

https://www.qualtrics.com/scc-update/

Questions people ask about Qualtrics

Where is Qualtrics's DPA?

Qualtrics publishes its customer data processing agreement at https://www.qualtrics.com/scc-update/. We last opened that link on 4 October 2026.

Is Qualtrics's DPA the same thing as a data processing addendum?

Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Qualtrics's is at https://www.qualtrics.com/scc-update/.

Where is Qualtrics's sub-processor list?

Qualtrics publishes the list of its own sub-processors at https://www.qualtrics.com/subprocessor-list/. We last opened that link on 4 October 2026.

Which legal entity does Qualtrics contract through?

Qualtrics LLC, registered in United States. That is the name to put in a record of processing or a sub-processor list, not the brand.

What covers a transfer of personal data to Qualtrics outside the EEA?

EU-US Data Privacy Framework (DPF). A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope. Whether that is enough for a particular processing operation is a judgement for the controller.

Qualtrics: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Qualtrics

What has changed, and when

Building your own sub-processor list?

Where to go next

Other analytics

Qualtrics: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Qualtrics

What has changed, and when

Building your own sub-processor list?

Where to go next

Other analytics