WhatsApp: DPA, subprocessors and transfers

What to put in your subprocessor list

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

Questions people ask about WhatsApp

Where is WhatsApp's DPA?

WhatsApp publishes its customer data processing agreement at https://www.whatsapp.com/legal/business-data-processing-terms.

Is WhatsApp'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. WhatsApp's is at https://www.whatsapp.com/legal/business-data-processing-terms.

Which legal entity does WhatsApp contract through?

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

Where is WhatsApp's trust center?

WhatsApp publishes it at https://www.whatsapp.com/security. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is WhatsApp's page, so we link to it rather than repeat what it says.

Where to go next

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.

• Vendors contracting from United States123 in the registry
• The vendor registryLegal entities, transfer mechanisms and DPA links, checked by a person
• Download the registry as a CSVFree, for a spreadsheet
• Guides for privacy practicesHow the work is actually done

Other communication

• AutomatticUS
• BirdNL
• BrevoFR
• CrispFR
• Customer.ioUS
• FreshdeskUS