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# Cloud Data Processing
Addendum (Customers)

Last modified: September 20, 2022

This is not the current version of this document and is provided for archival
purposes.

View the current version

This Cloud Data Processing Addendum including its
appendices (“*Addendum*”) is incorporated into the
Agreement(s) under which Google has agreed to provide
Google Cloud Platform, Google Workspace, or Cloud
Identity (each as defined below), as applicable (the
“*Services*”), to Customer. This Addendum was
formerly known as the “Data Processing and Security
Terms” under an Agreement for Google Cloud Platform and
the “Data Processing Amendment” under an Agreement for
Google Workspace or Cloud Identity.

1. Commencement

This Addendum will be effective and replace any terms
previously applicable to the processing of Customer Data,
including any Data Processing and Security Terms or Data
Processing Amendment, from the Addendum Effective Date (as
defined below).

2. Definitions

2.1 Capitalized terms used but not defined in this
Addendum have the meaning given to them in the Agreement:

   - *Account* has the meaning given in the applicable
Agreement or, if no such meaning is given, means
Customer’s Google Cloud Platform account, Google
Workspace account or Cloud Identity account, as
applicable.

   - *Addendum* *Effective Date* means the
date on which Customer accepted, or the parties
otherwise agreed to, this Addendum.

   - *Additional Security Controls *means
security resources, features, functionality and/or
controls that Customer may use at its option and/or as
it determines, including the Admin Console, encryption,
logging and monitoring, identity and access management,
security scanning, and firewalls.

   - *Adequate Country *means:

(a) for data processed
subject to the EU GDPR: the EEA, or a country or territory
recognized as ensuring adequate protection under the EU
GDPR;

(b) for data processed
subject to the UK GDPR: the UK, or a country or territory
recognized as ensuring adequate protection under the UK
GDPR and the Data Protection Act 2018; and/or

(c) for data processed
subject to the Swiss FDPA: Switzerland, or a country or
territory that is: (i) included in the list of the states
whose legislation ensures adequate protection as published
by the Swiss Federal Data Protection and Information
Commissioner, or (ii) recognized as ensuring adequate
protection by the Swiss Federal Council under the Swiss
FDPA;

in each case, other than on
the basis of an optional data protection framework.

   - *Alternative Transfer Solution* means a
solution, other than SCCs, that enables the lawful
transfer of personal data to a third country in
accordance with European Data Protection Law, for
example a data protection framework recognized as
ensuring that participating entities provide adequate
protection.

   - *Audited Services* means the then-current
Services indicated as being in-scope for the relevant
certification or report at
https://cloud.google.com/security/compliance/services-in-scope.
Google may not remove any Services from this URL unless
those Services have been discontinued in accordance with
the applicable Agreement.

   - *Cloud Identity* means the Cloud Identity
Services described at
https://cloud.google.com/terms/identity/user-features,
when purchased under a standalone Agreement.

   - *Customer Data* has the meaning given in the
applicable Agreement or, if no such meaning is given,
means:

(a) data provided by or on
behalf of Customer or its End Users via Google Cloud
Platform under the Account; or

(b) data submitted, stored,
sent or received by or on behalf of Customer or its End
Users via Google Workspace or Cloud Identity under the
Account.

   - *Customer Personal Data* means the personal
data contained within the Customer Data, including any
special categories of personal data defined under
European Data Protection Law.

   - *Customer SCCs* means the SCCs
(Controller-to-Processor), the SCCs
(Processor-to-Processor) and/or the SCCs
(Processor-to-Controller), as applicable.

   - *Data Incident* means a breach of Google’s
security leading to the accidental or unlawful
destruction, loss, alteration, unauthorized disclosure
of, or access to, Customer Data on systems managed by or
otherwise controlled by Google.

   - *EEA* means the European Economic Area.

   - *EMEA *means Europe, the Middle East and
Africa.

   - *EU GDPR* means Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to
the processing of personal data and on the free movement
of such data, and repealing Directive 95/46/EC.

   - *European Data Protection Law* means, as
applicable: (a) the GDPR; and/or (b) the Swiss FDPA.

   - *European Law* means, as applicable: (a) EU or EU
Member State law (if the EU GDPR applies to the
processing of Customer Personal Data); and (b) the law
of the UK or a part of the UK (if the UK GDPR applies to
the processing of Customer Personal Data).

   - *GDPR* means, as applicable: (a) the EU
GDPR; and/or (b) the UK GDPR.

   - *Google Cloud Platform* means the Google Cloud
Platform services described at

https://cloud.google.com/terms/services,
excluding any Third-Party Offerings.

   - *Google Workspace *means the Google Workspace or
Google Workspace for Education services described at

https://workspace.google.com/terms/user_features.html,
as applicable.

   - *Google’s Third Party Auditor* means a
Google-appointed, qualified and independent third party
auditor, whose then-current identity Google will
disclose to Customer.

   - *Instructions* has the meaning given in
Section 5.2.1 (Compliance with Customer’s Instructions).

   - *Non-European Data Protection Law* means
data protection or privacy laws in force outside the
EEA, the UK and Switzerland.

   - *Notification Email Address* means the email
address(es) designated by Customer in the Admin Console
or Order Form to receive certain notifications from
Google. Customer is responsible for using the Admin
Console to ensure that its Notification Email Address
remains current and valid.

   - *SCCs* means the Customer SCCs and/or SCCs
(Processor-to-Processor, Google Exporter), as
applicable.

   - *SCCs (Controller-to-Processor)* means the
terms at:

https://cloud.google.com/terms/sccs/eu-c2p

   - *SCCs (Processor-to-Controller)* means the
terms at:

https://cloud.google.com/terms/sccs/eu-p2c

   - *SCCs (Processor-to-Processor)* means the
terms at:

https://cloud.google.com/terms/sccs/eu-p2p

*SCCs (Processor-to-Processor, Google Exporter)* means
the terms at:

https://cloud.google.com/terms/sccs/eu-p2p-google-exporter

   - *Security Documentation* means all documents and
information made available by Google under Section 7.5.1
(Reviews of Security Documentation).

   - *Security Measures* has the meaning given in
Section 7.1.1 (Google’s Security Measures).

   - *Subprocessor* means a third party authorized as
another processor under this Addendum to have logical
access to and process Customer Data in order to provide
parts of the Services and TSS.

   - *Supervisory Authority *means, as
applicable: (a) a “supervisory authority” as defined in
the EU GDPR; and/or (b) the “Commissioner” as defined in
the UK GDPR and/or the Swiss FDPA.

   - *Swiss FDPA* means the Federal Data
Protection Act of 19 June 1992 (Switzerland).

   - *Term* means the period from the Addendum
Effective Date until the end of Google’s provision of
the Services, including, if applicable, any period
during which provision of the Services may be suspended
and any post-termination period during which Google may
continue providing the Services for transitional
purposes.

   - *UK GDPR* means the EU GDPR as amended and
incorporated into UK law under the UK European Union
(Withdrawal) Act 2018, and applicable secondary
legislation made under that Act.

2.2 The terms “personal data”, “data subject”,
“processing”, “controller” and “processor” as used in this
Addendum have the meanings given in the GDPR irrespective
of whether European Data Protection Law or Non-European
Data Protection Law applies.

3. Duration

Regardless of whether the applicable Agreement has
terminated or expired, this Addendum will remain in effect
until, and automatically expire when, Google deletes all
Customer Data as described in this Addendum.

4. Scope of Data Protection Law

4.1 *Application of European Law*. The parties
acknowledge that European Data Protection Law will apply
to the processing of Customer Personal Data if, for
example:

a. the processing is
carried out in the context of the activities of an
establishment of Customer in the territory of the EEA or
the UK; and/or

b. the Customer Personal Data
is personal data relating to data subjects who are in the
EEA or the UK and the processing relates to the offering
to them of goods or services in the EEA or the UK, or the
monitoring of their behavior in the EEA or the UK.

4.2 *Application of Non-European Law*. The parties
acknowledge that Non-European Data Protection Law may also
apply to the processing of Customer Personal Data.

4.3 *Application of Addendum*. Except to the
extent this Addendum states otherwise, this Addendum will
apply irrespective of whether European Data Protection Law
or Non-European Data Protection Law applies to the
processing of Customer Personal Data.

5. Processing of Data

5.1 *Roles and Regulatory Compliance; Authorization*.

5.1.1 *Processor and Controller Responsibilities*.
If European Data Protection Law applies to the processing
of Customer Personal Data:

a. the subject matter and
details of the processing are described in Appendix 1;

b. Google is a processor of
that Customer Personal Data under European Data Protection
Law;

c. Customer is a controller
or processor, as applicable, of that Customer Personal
Data under European Data Protection Law; and

d. each party will comply
with the obligations applicable to it under European Data
Protection Law with respect to the processing of that
Customer Personal Data.

5.1.2 *Processor Customers*. If European Data
Protection Law applies to the processing of Customer
Personal Data and Customer is a processor:

a. Customer warrants on an
ongoing basis that the relevant controller has authorized:
(i) the Instructions, (ii) Customer’s appointment of
Google as another processor, and (iii) Google’s engagement
of Subprocessors as described in Section 11
(Subprocessors);

b. Customer will immediately
forward to the relevant controller any notice provided by
Google under Sections 5.2.2 (Instruction Notifications),
7.2.1 (Incident Notification), 9.2.1 (Responsibility for
Requests), 11.4 (Opportunity to Object to Subprocessor
Changes) or that refers to any SCCs; and

c. Customer may:

i. request access for the
relevant controller to the SOC Reports in accordance with
Section 7.5.3(a); and

ii. make available to the
relevant controller any other information made available
by Google under Sections 10.4 (Supplementary Measures and
Information), 10.6 (Data Center Information) and 11.2
(Information about Subprocessors).

5.1.3
*Responsibilities under Non-European Law.* If
Non-European Data Protection Law applies to either party’s
processing of Customer Personal Data, the relevant party
will comply with any obligations applicable to it under
that law with respect to the processing of that Customer
Personal Data.

5.2 *Scope of Processing*.

5.2.1 *Compliance with Customer’s Instructions*.
Customer instructs Google to process Customer Data in
accordance with the applicable Agreement (including this
Addendum) and applicable law only: (a) to provide, secure,
and monitor the Services and TSS; and (b) as further
specified via (i) Customer’s use of the Services
(including the Admin Console and other Services
functionality) and TSS, and (ii) any other written
instructions given by Customer and acknowledged by Google
as constituting instructions under this Addendum
(collectively, the “*Instructions*”). Google will
comply with the Instructions unless prohibited by European
Law.

5.2.2 *Instruction Notifications*. Without
prejudice to Google’s obligations under Section 5.2.1
(Compliance with Customer’s Instructions) or any other
rights or obligations of either party under the applicable
Agreement, Google will immediately notify Customer if, in
Google’s opinion: (a) European Law prohibits Google from
complying with an Instruction; (b) an Instruction does not
comply with European Data Protection Law; or (c) Google is
otherwise unable to comply with an Instruction, in each
case unless such notice is prohibited by European
Law.

5.3 *Additional Products*. If Google at its
option makes Additional Products available to Customer for
use with Google Workspace or Cloud Identity in accordance
with applicable Additional Product Terms:

a. Customer may enable or
disable Additional Products via the Admin Console and will
not need to use Additional Products in order to use Google
Workspace or Cloud Identity; and

b. if Customer opts to
install any Additional Products or to use them with Google
Workspace or Cloud Identity, the Additional Products may
access Customer Data as required to interoperate with
Google Workspace or Cloud Identity (as applicable).

For clarity, this Addendum does not apply to the
processing of personal data in connection with the
provision of any Additional Products installed or used by
Customer, including personal data transmitted to or from
such Additional Products.

6. Data Deletion

6.1 *Deletion by Customer*. Google will enable
Customer to delete Customer Data during the Term in a
manner consistent with the functionality of the Services.
If Customer uses the Services to delete any Customer Data
during the Term and that Customer Data cannot be recovered
by Customer, this use will constitute an Instruction to
Google to delete the relevant Customer Data from Google’s
systems in accordance with applicable law. Google will
comply with this Instruction as soon as reasonably
practicable and within a maximum period of 180 days,
unless European Law requires storage.

6.2 *Return or Deletion When Term Ends*. If
Customer wishes to retain any Customer Data after the end
of the Term, it may instruct Google in accordance with
Section 9.1 (Access; Rectification; Restricted Processing;
Portability) to return that data during the Term. Subject
to Section 6.3 (Deferred Deletion Instruction), Customer
instructs Google to delete all remaining Customer Data
(including existing copies) from Google’s systems at the
end of the Term in accordance with applicable law. After a
recovery period of up to 30 days from that date, Google
will comply with this Instruction as soon as reasonably
practicable and within a maximum period of 180 days,
unless European Law requires storage.

   - 6.3. *Deferred Deletion Instruction*. To the extent
any Customer Data covered by the deletion instruction
described in Section 6.2 (Return or Deletion When Term
Ends) is also processed, when the applicable Term under
Section 6.2 expires, in relation to an Agreement with a
continuing Term, such deletion instruction will take
effect with respect to such Customer Data only when the
continuing Term expires. For clarity, this Addendum will
continue to apply to such Customer Data until its deletion
by Google.

7. Data Security

7.1 *Google’s Security Measures, Controls and Assistance*.

7.1.1 *Google’s Security Measures*. Google will
implement and maintain technical,  organizational and
physical measures to protect Customer Data against
accidental or unlawful destruction, loss, alteration,
unauthorized disclosure or access as described in Appendix
2 (the “*Security Measures*”). The Security Measures
include measures to encrypt Customer Data; to help ensure
ongoing confidentiality, integrity, availability and
resilience of Google’s systems and services; to help
restore timely access to Customer Data following an
incident; and for regular testing of effectiveness. Google
may update the Security Measures from time to time
provided that such updates do not result in a material
reduction of the security of the Services.

7.1.2 *Access and Compliance*. Google will: (a)
authorize its employees, contractors and Subprocessors to
access Customer Data only as strictly necessary to comply
with Instructions; (b) take appropriate steps to ensure
compliance with the Security Measures by its employees,
contractors and Subprocessors to the extent applicable to
their scope of performance; and (c) ensure that all
persons authorized to process Customer Data are under an
obligation of confidentiality.

7.1.3 *Additional Security Controls*. Google
will make Additional Security Controls available to: (a)
allow Customer to take steps to secure Customer Data; and
(b) provide Customer with information about securing,
accessing and using Customer Data.

7.1.4 *Google’s Security Assistance*. Google
will (taking into account the nature of the processing of
Customer Personal Data and the information available to
Google) assist Customer in ensuring compliance with its
(or, where Customer is a processor, the relevant
controller’s) obligations under Articles 32 to 34 of the
GDPR, by:

a. implementing and
maintaining the Security Measures in accordance with
Section 7.1.1 (Google’s Security Measures);

b. making Additional Security
Controls available to Customer in accordance with Section
7.1.3 (Additional Security Controls);

c. complying with the terms
of Section 7.2 (Data Incidents);

d. providing Customer with
the Security Documentation in accordance with Section
7.5.1 (Reviews of Security Documentation) and the
information contained in the applicable Agreement
(including this Addendum); and

e. if subsections (a)-(d)
above are insufficient for Customer (or the relevant
controller) to comply with such obligations, upon
Customer’s request, providing Customer with additional
reasonable cooperation and assistance.

7.2 *Data Incidents*.

7.2.1 *Incident Notification*. Google will
notify Customer promptly and without undue delay after
becoming aware of a Data Incident, and promptly take
reasonable steps to minimize harm and secure Customer
Data.

7.2.2 *Details of Data Incident*. Google’s
notification of a Data Incident will describe: the nature
of the Data Incident including the Customer resources
impacted; the measures Google has taken, or plans to take,
to address the Data Incident and mitigate its potential
risk; the measures, if any, Google recommends that
Customer take to address the Data Incident; and details of
a contact point where more information can be obtained. If
it is not possible to provide all such information at the
same time, Google’s initial notification will contain the
information then available and further information will be
provided without undue delay as it becomes available.

7.2.3 *Delivery of Notification*.
Notification(s) of any Data Incident(s) will be delivered
to the Notification Email Address.

7.2.4 *No Assessment of Customer Data by Google*.
Google has no obligation to assess Customer Data in order
to identify information subject to any specific legal
requirements.

7.2.5 *No Acknowledgement of Fault by Google*.
Google’s notification of or response to a Data Incident
under this Section 7.2 (Data Incidents) will not be
construed as an acknowledgement by Google of any fault or
liability with respect to the Data Incident.

7.3 *Customer’s Security Responsibilities and Assessment*.

7.3.1 *Customer’s Security Responsibilities*.
Without prejudice to Google’s obligations under Sections
7.1 (Google’s Security Measures, Controls and Assistance)
and 7.2 (Data Incidents), and elsewhere in the applicable
Agreement, Customer is responsible for its use of the
Services and its storage of any copies of Customer Data
outside Google’s or Google’s Subprocessors’ systems,
including:

a. using the Services and
Additional Security Controls to ensure a level of security
appropriate to the risk to the Customer Data;

b. securing the account
authentication credentials, systems and devices Customer
uses to access the Services; and

c. backing up or retaining
copies of its Customer Data as appropriate.

7.3.2 *Customer’s Security Assessment*.
Customer agrees that the Services, Security Measures
implemented and maintained by Google, Additional Security
Controls and Google’s commitments under this Section 7
(Data Security) provide a level of security appropriate to
the risk to Customer Data (taking into account the state
of the art, the costs of implementation and the nature,
scope, context and purposes of the processing of Customer
Personal Data as well as the risks to individuals).

7.4 *Compliance Certifications and SOC Reports*.
Google will maintain at least the following for the
Audited Services in order to evaluate the continued
effectiveness of the Security Measures: (a) certificates
for ISO 27001, ISO 27017 and ISO 27018 and, for Google
Cloud Platform, a PCI DSS Attestation of Compliance (the
“*Compliance Certifications*”); and (b) SOC 2 and SOC
3 reports produced by Google’s Third Party Auditor and
updated annually based on an audit performed at least once
every 12 months (the “*SOC Reports*”). Google may add
standards at any time. Google may replace a Compliance
Certification or SOC Report with an equivalent or enhanced
alternative.

7.5 *Reviews and Audits of Compliance*.

7.5.1 *Reviews of Security Documentation*.
Google will make the Compliance Certifications and the SOC
Reports available for review by Customer to demonstrate
compliance by Google with its obligations under this
Addendum.

7.5.2 *Customer’s Audit Rights*.

a. If European Data
Protection Law applies to the processing of Customer
Personal Data, Google will allow Customer or an
independent auditor appointed by Customer to conduct
audits (including inspections) to verify Google’s
compliance with its obligations under this Addendum in
accordance with Section 7.5.3 (Additional Business Terms
for Reviews and Audits). During an audit, Google will make
available all information necessary to demonstrate such
compliance and contribute to the audit as described in
Section 7.4 (Compliance Certifications and SOC Reports)
and this Section 7.5 (Reviews and Audits of Compliance).

b. If Customer SCCs apply as
described in Section 10.2 (Restricted European Transfers),
Google will allow Customer (or an independent auditor
appointed by Customer) to conduct audits as described in
those SCCs and, during an audit, make available all
information required by those SCCs, both in accordance
with Section 7.5.3 (Additional Business Terms for Reviews
and Audits).

c. Customer may conduct an
audit to verify Google’s compliance with its obligations
under this Addendum by reviewing the Security
Documentation (which reflects the outcome of audits
conducted by Google’s Third Party Auditor).

7.5.3 *Additional Business Terms for Reviews and Audits*.

a. Customer must send any
requests for reviews of the SOC 2 report under Section
5.1.2(c)(i) or 7.5.1, or audits under Section 7.5.2(a) or
7.5.2(b), to Google’s Cloud Data Protection Team as
described in Section 12 (Cloud Data Protection Team;
Processing Records).

b. Following receipt by
Google of a request under Section 7.5.3(a), Google and
Customer will discuss and agree in advance on: (i) the
reasonable date(s) of and security and confidentiality
controls applicable to any review of the SOC 2 report
under Section 5.1.2(c)(i) or 7.5.1; and (ii) the
reasonable start date, scope and duration of and security
and confidentiality controls applicable to any audit under
Section 7.5.2(a) or 7.5.2(b).

c. Google may charge a fee
(based on Google’s reasonable costs) for any audit under
Section 7.5.2(a) or 7.5.2(b). Google will provide Customer
with further details of any applicable fee, and the basis
of its calculation, in advance of any such audit. Customer
will be responsible for any fees charged by any auditor
appointed by Customer to execute any such audit.

d.  Google may object in
writing to an auditor appointed by Customer to conduct any
audit under Section 7.5.2(a) or 7.5.2(b) if the auditor
is, in Google’s reasonable opinion, not suitably qualified
or independent, a competitor of Google, or otherwise
manifestly unsuitable. Any such objection by Google will
require Customer to appoint another auditor or conduct the
audit itself.

8. Impact Assessments and Consultations

Google will (taking into account the nature of the
processing and the information available to Google) assist
Customer in ensuring compliance with its (or, where
Customer is a processor, the relevant controller’s)
obligations under Articles 35 and 36 of the GDPR, by:

a. providing Additional
Security Controls in accordance with Section 7.1.3
(Additional Security Controls) and the Security
Documentation in accordance with Section 7.5.1 (Reviews of
Security Documentation);

b. providing the information
contained in the applicable Agreement (including this
Addendum); and

c. if subsections (a) and (b)
above are insufficient for Customer (or the relevant
controller) to comply with such obligations, upon
Customer’s request, providing Customer with additional
reasonable cooperation and assistance.

9. Access etc.; Data Subject Rights; Data Export

9.1
*Access; Rectification; Restricted Processing; Portability*.
During the Term, Google will enable Customer, in a manner
consistent with the functionality of the Services, to
access, rectify and restrict processing of Customer Data,
including via the deletion functionality provided by
Google as described in Section 6.1 (Deletion by Customer),
and to export Customer Data. If Customer becomes aware
that any Customer Personal Data is inaccurate or outdated,
Customer will be responsible for using such functionality
to rectify or delete that data if required by applicable
European Data Protection Law.

9.2 *Data Subject Requests*.

9.2.1 *Responsibility for Requests*. During the
Term, if Google’s Cloud Data Protection Team receives a
request from a data subject that relates to Customer
Personal Data and identifies Customer, Google will: (a)
advise the data subject to submit their request to
Customer; (b) promptly notify Customer; and (c) not
otherwise respond to that data subject’s request without
authorization from Customer. Customer will be responsible
for responding to any such request including, where
necessary, by using the functionality of the Services.

9.2.2 *Google’s Data Subject Request Assistance*.
Google will (taking into account the nature of the
processing of Customer Personal Data) assist Customer in
fulfilling its (or, where Customer is a processor, the
relevant controller’s) obligations under Chapter III of
the GDPR to respond to requests for exercising the data
subject’s rights by:

a. providing Additional
Security Controls in accordance with Section 7.1.3
(Additional Security Controls);

b. complying with Sections
9.1 (Access; Rectification; Restricted Processing;
Portability) and 9.2.1 (Responsibility for Requests); and

c. if subsections (a) and (b)
above are insufficient for Customer (or the relevant
controller) to comply with such obligations, upon
Customer’s request, providing Customer with additional
reasonable cooperation and assistance.

10. Data Transfers

10.1* Data Storage and Processing Facilities*.
Subject to Google’s data location commitments under the
Service Specific Terms and the remainder of this Section
10 (Data Transfers), Customer Data may be processed in any
country in which Google or its Subprocessors maintain
facilities.

10.2 *Restricted European Transfers*. The parties
acknowledge that European Data Protection Law does not
require SCCs or an Alternative Transfer Solution in order
for Customer Personal Data to be processed in or
transferred to an Adequate Country.  If Customer
Personal Data is transferred to any other country and
European Data Protection Law applies to the transfers (as
certified by Customer under Section 10.3 (Certification by
Non-EMEA Customers) if its billing address is outside
EMEA) (“*Restricted European Transfers*”), then:

a. if Google has adopted an
Alternative Transfer Solution for any Restricted European
Transfers, then Google will inform Customer of the
relevant solution and ensure that such Restricted European
Transfers are made in accordance with it; and/or

b. if Google has not adopted,
or informs Customer that Google is no longer adopting, an
Alternative Transfer Solution for any Restricted European
Transfers, then:

i. if Google’s address is in
an Adequate Country:

A. the SCCs
(Processor-to-Processor, Google Exporter) will apply with
respect to such Restricted European Transfers from Google
to Subprocessors; and

B. in addition, if
Customer’s billing address is not in an Adequate Country,
the SCCs (Processor-to Controller) will apply (regardless
of whether Customer is a controller and/or processor) with
respect to such Restricted European Transfers between
Google and Customer; or

ii. if Google’s address is
not in an Adequate Country, the SCCs
(Controller-to-Processor) and/or SCCs
(Processor-to-Processor) will apply (according to whether
Customer is a controller and/or processor) with respect to
such Restricted European Transfers between Google and
Customer.

10.3 *Certification by Non-EMEA Customers*. If
Customer’s billing address is outside EMEA, and the
processing of Customer Personal Data is subject to
European Data Protection Law, Customer will certify as
such, and identify its competent Supervisory Authority,
via the Admin Console for Google Cloud Platform or Google
Workspace and Cloud Identity, as applicable.

10.4 *Supplementary Measures and Information*.
Google will provide Customer with information relevant to
Restricted European Transfers, including information about
Additional Security Controls and other supplementary
measures to protect Customer Personal Data:

a. as described in Section
7.5.1 (Reviews of Security Documentation);

b. in the documentation for
the Services, available at

https://cloud.google.com/docs;
and

c. in the Google Cloud Trust
and Security website, available at

https://cloud.google.com/security.

10.5 *Termination*. If Customer concludes,
based on its current or intended use of the Services, that
the Alternative Transfer Solution and/or SCCs, as
applicable, do not provide appropriate safeguards for
Customer Personal Data, then Customer may immediately
terminate the applicable Agreement for convenience by
notifying Google.

10.6 *Data Center Information*. The locations
of Google data centers are described at:

a.

https://cloud.google.com/about/locations/
for Google Cloud Platform; and

b.

https://www.google.com/about/datacenters/locations/
for Google Workspace and Cloud Identity.

11. Subprocessors

11.1 *Consent to Subprocessor Engagement*.
Customer specifically authorizes the engagement as
Subprocessors of those entities disclosed under Section
11.2 (Information about Subprocessors) as of the Addendum
Effective Date. In addition, without prejudice to Section
11.4 (Opportunity to Object to Subprocessor Changes),
Customer generally authorizes the engagement of other
third parties as Subprocessors
(“*New Subprocessors*”).

11.2 *Information about Subprocessors*. Names,
locations and activities of Subprocessors are described
at:

a.

https://cloud.google.com/terms/subprocessors
for Google Cloud Platform; and

b.

https://workspace.google.com/intl/en/terms/subprocessors.html
for Google Workspace and Cloud Identity.

11.3 *Requirements for Subprocessor Engagement*.
When engaging any Subprocessor, Google will:

a. ensure via a written
contract that:

i. the Subprocessor only
accesses and uses Customer Data to the extent required to
perform the obligations subcontracted to it, and does so
in accordance with the applicable Agreement (including
this Addendum); and

ii. if the processing of
Customer Personal Data is subject to European Data
Protection Law, the data protection obligations described
in this Addendum (as referred to in Article 28(3) of the
GDPR, if applicable), are imposed on the Subprocessor; and

b. remain fully liable for
all obligations subcontracted to, and all acts and
omissions of, the Subprocessor.

11.4 *Opportunity to Object to Subprocessor Changes*.

a. When any New Subprocessor
is engaged during the Term, Google will, at least 30 days
before the New Subprocessor starts processing any Customer
Data, notify Customer of the engagement (including the
name, location and activities of the New Subprocessor).

b. Customer may, within 90
days after being notified of the engagement of a New
Subprocessor, object by immediately terminating the
applicable Agreement for convenience by notifying Google.

12. Cloud Data Protection Team; Processing Records

12.1 *Cloud Data Protection Team*. Google’s
Cloud Data Protection Team will provide prompt and
reasonable assistance with any Customer queries related to
processing of Customer Data under the applicable Agreement
and can be contacted:

a. at

https://support.google.com/cloud/contact/dpo
for Google Cloud Platform;

b. at

https://support.google.com/a/contact/googlecloud_dpr
for Google Workspace and Cloud Identity (while
Administrators are signed in to their Admin Account); or

c. as described in the
Notices section of the applicable Agreement.

12.2 *Google’s Processing Records*. Google will
keep appropriate documentation of its processing
activities as required by the GDPR. To the extent the GDPR
requires Google to collect and maintain records of certain
information relating to Customer, Customer will use the
Admin Console to supply such information and keep it
accurate and up-to-date. Google may make any such
information available to the Supervisory Authorities if
required by the GDPR.

12.3 *Controller Requests*. During the Term, if
Google’s Cloud Data Protection Team receives a request or
instruction from a third party purporting to be a
controller of Customer Personal Data, Google will advise
the third party to contact Customer.

13. Interpretation

13.1 *Precedence*.

a. To the extent of any
conflict or inconsistency between:

i. this Addendum and the
remainder of the Agreement, this Addendum will prevail;
and

ii. any Customer SCCs (which
are incorporated by reference into this Addendum) and the
remainder of the Agreement (including this Addendum), the
Customer SCCs will prevail.

b. For clarity, if Customer
has entered more than one Agreement, this Addendum will
amend each of the Agreements separately.

13.2 *Legacy UK SCCs*. The supplementary terms for
UK GDPR transfers in the SCCs will, as of 21 September
2022, supersede and terminate any standard contractual
clauses approved under the UK GDPR or Data Protection Act
2018 and previously entered into by Customer and Google.

13.3 *No Modification of SCCs*. Nothing in the
Agreement (including this Addendum) is intended to modify
or contradict any SCCs or prejudice the fundamental rights
or freedoms of data subjects under European Data
Protection Law.

Appendix 1: Subject Matter and Details of the Data
Processing

*Subject Matter*

Google’s provision of the Services and TSS to Customer.

*Duration of the Processing*

The Term plus the period from the end of the Term until
deletion of all Customer Data by Google in accordance with
this Addendum.

*Nature and Purpose of the Processing*

Google will process Customer Personal Data for the
purposes of providing the Services and TSS to Customer in
accordance with this Addendum.

*Categories of Data*

Data relating to individuals provided to Google via the
Services, by (or at the direction of) Customer or by its
End Users.

*Data Subjects*

Data subjects include the individuals about whom data is
provided to Google via the  Services by (or at the
direction of) Customer or by its End Users.

Appendix 2: Security Measures

As from the Addendum Effective Date, Google will
implement and maintain the Security Measures described in
this Appendix 2.

**1. Data Center and Network Security**

*(a) Data Centers.*

*Infrastructure*. Google maintains geographically
distributed data centers. Google stores all production
data in physically secure data centers.

*Redundancy*. Infrastructure systems have been
designed to eliminate single points of failure and
minimize the impact of anticipated environmental risks.
Dual circuits, switches, networks or other necessary
devices help provide this redundancy. The Services are
designed to allow Google to perform certain types of
preventative and corrective maintenance without
interruption. All environmental equipment and facilities
have documented preventative maintenance procedures that
detail the process for and frequency of performance in
accordance with the manufacturer’s or internal
specifications. Preventative and corrective maintenance of
the data center equipment is scheduled through a standard
change process according to documented procedures.

*Power*. The data center electrical power systems
are designed to be redundant and maintainable without
impact to continuous operations, 24 hours a day, 7 days a
week. In most cases, a primary as well as an alternate
power source, each with equal capacity, is provided for
critical infrastructure components in the data center.
Backup power is provided by various mechanisms such as
uninterruptible power supplies (UPS) batteries, which
supply consistently reliable power protection during
utility brownouts, blackouts, over voltage, under voltage,
and out-of-tolerance frequency conditions. If utility
power is interrupted, backup power is designed to provide
transitory power to the data center, at full capacity, for
up to 10 minutes until the backup generator systems take
over. The backup generators are capable of automatically
starting up within seconds to provide enough emergency
electrical power to run the data center at full capacity
typically for a period of days.

*Server Operating Systems*. Google servers use a
Linux based implementation customized for the application
environment. Data is stored using proprietary algorithms
to augment data security and redundancy. Google employs a
code review process to increase the security of the code
used to provide the Services and enhance the security
products in production environments.

*Businesses Continuity*. Google has designed and
regularly plans and tests its business continuity
planning/disaster recovery programs.

(*b) Networks and Transmission.*

*Data Transmission*. Data centers are typically
connected via high-speed private links to provide secure
and fast data transfer between data centers. This is
designed to prevent data from being read, copied, altered
or removed without authorization during electronic
transfer or transport or while being recorded onto data
storage media. Google transfers data via Internet standard
protocols.

*External Attack Surface*. Google employs multiple
layers of network devices and intrusion detection to
protect its external attack surface. Google considers
potential attack vectors and incorporates appropriate
purpose built technologies into external facing systems.

*Intrusion Detection*. Intrusion detection is
intended to provide insight into ongoing attack activities
and provide adequate information to respond to incidents.
Google’s intrusion detection involves:

   - tightly controlling the size and make-up of Google’s
attack surface through preventative measures;

   - employing intelligent detection controls at data entry
points; and

   - employing technologies that automatically remedy
certain dangerous situations.

*Incident Response*. Google monitors a variety of
communication channels for security incidents, and
Google’s security personnel will react promptly to known
incidents.

*Encryption Technologies*. Google makes HTTPS
encryption (also referred to as SSL or TLS connection)
available. Google servers support ephemeral elliptic curve
Diffie-Hellman cryptographic key exchange signed with RSA
and ECDSA. These perfect forward secrecy (PFS) methods
help protect traffic and minimize the impact of a
compromised key, or a cryptographic breakthrough.

**2. Access and Site Controls**

*(a) Site Controls.*

*On-site Data Center Security Operation*. Google’s
data centers maintain an on-site security operation
responsible for all physical data center security
functions 24 hours a day, 7 days a week. The on-site
security operation personnel monitor closed circuit TV
(CCTV) cameras and all alarm systems. On-site security
operation personnel perform internal and external patrols
of the data center regularly.

*Data Center Access Procedures*. Google maintains
formal access procedures for allowing physical access to
the data centers. The data centers are housed in
facilities that require electronic card key access, with
alarms that are linked to the on-site security operation.
All entrants to the data center are required to identify
themselves as well as show proof of identity to on-site
security operations. Only authorized employees,
contractors and visitors are allowed entry to the data
centers. Only authorized employees and contractors are
permitted to request electronic card key access to these
facilities. Data center electronic card key access
requests must be made through e-mail, and require the
approval of the requestor’s manager and the data center
director. All other entrants requiring temporary data
center access must: (i) obtain approval in advance from
the data center managers for the specific data center and
internal areas they wish to visit; (ii) sign in at on-site
security operations; and (iii) reference an approved data
center access record identifying the individual as
approved.

*On-site Data Center Security Devices*. Google’s
data centers employ a dual authentication access control
system that is linked to a system alarm. The access
control system monitors and records each individual’s
electronic card key and when they access perimeter doors,
shipping and receiving, and other critical areas.
Unauthorized activity and failed access attempts are
logged by the access control system and investigated, as
appropriate. Authorized access throughout the business
operations and data centers is restricted based on zones
and the individual’s job responsibilities. The fire doors
at the data centers are alarmed. CCTV cameras are in
operation both inside and outside the data centers. The
positioning of the cameras has been designed to cover
strategic areas including, among others, the perimeter,
doors to the data center building, and shipping/receiving.
On-site security operations personnel manage the CCTV
monitoring, recording and control equipment. Secure cables
throughout the data centers connect the CCTV equipment.
Cameras record on site via digital video recorders 24
hours a day, 7 days a week. The surveillance records are
retained for up to 30 days based on activity.

*(b) Access Control.*

*Infrastructure Security Personnel*. Google has, and
maintains, a security policy for its personnel, and
requires security training as part of the training package
for its personnel. Google’s infrastructure security
personnel are responsible for the ongoing monitoring of
Google’s security infrastructure, the review of the
Services, and responding to security incidents.

*Access Control and Privilege Management*.
Customer’s administrators and End Users must authenticate
themselves via a central authentication system or via a
single sign on system in order to use the Services.

*Internal Data Access Processes and Policies – Access Policy*.
Google’s internal data access processes and policies are
designed to prevent unauthorized persons and/or systems
from gaining access to systems used to process Customer
Data. Google designs its systems to (i) only allow
authorized persons to access data they are authorized to
access; and (ii) ensure that Customer Data cannot be read,
copied, altered or removed without authorization during
processing, use and after recording. The systems are
designed to detect any inappropriate access. Google
employs a centralized access management system to control
personnel access to production servers, and only provides
access to a limited number of authorized personnel.
Google’s authentication and authorization systems utilize
SSH certificates and security keys, and are designed to
provide Google with secure and flexible access mechanisms.
These mechanisms are designed to grant only approved
access rights to site hosts, logs, data and configuration
information. Google requires the use of unique user IDs,
strong passwords, two factor authentication and carefully
monitored access lists to minimize the potential for
unauthorized account use. The granting or modification of
access rights is based on: the authorized personnel’s job
responsibilities; job duty requirements necessary to
perform authorized tasks; and a need to know basis. The
granting or modification of access rights must also be in
accordance with Google’s internal data access policies and
training. Approvals are managed by workflow tools that
maintain audit records of all changes. Access to systems
is logged to create an audit trail for accountability.
Where passwords are employed for authentication (e.g.
login to workstations), password policies that follow at
least industry standard practices are implemented. These
standards include restrictions on password reuse and
sufficient password strength. For access to extremely
sensitive information (e.g. credit card data), Google uses
hardware tokens.

**3. Data**

(a) *Data Storage, Isolation and Logging*.
Google stores data in a multi-tenant environment on
Google-owned servers. Subject to any Instructions to the
contrary (e.g. in the form of a data location selection),
Google replicates Customer Data between multiple
geographically dispersed data centers. Google also
logically isolates Customer Data and, for Google Workspace
and Cloud Identity: (i) Google logically separates each
End User’s data from the data of other End Users; and (ii)
data for an authenticated End User will not be displayed
to another End User (unless the former End User or an
Administrator allows the data to be shared). Customer will
be given control over specific data sharing policies.
Those policies, in accordance with the functionality of
the Services, will enable Customer to determine the
product sharing settings applicable to its End Users for
specific purposes. Customer may choose to use logging
functionality that Google makes available via the
Services.

(b) *Decommissioned Disks and Disk Erase Policy*.
Disks containing data may experience performance issues,
errors or hardware failure that lead them to be
decommissioned (“Decommissioned Disk”). Every
Decommissioned Disk is subject to a series of data
destruction processes (the “Disk Erase Policy”) before
leaving Google’s premises either for reuse or destruction.
Decommissioned Disks are erased in a multi-step process
and verified complete by at least two independent
validators. The erase results are logged by the
Decommissioned Disk’s serial number for tracking. Finally,
the erased Decommissioned Disk is released to inventory
for reuse and redeployment. If, due to hardware failure,
the Decommissioned Disk cannot be erased, it is securely
stored until it can be destroyed. Each facility is audited
regularly to monitor compliance with the Disk Erase
Policy.

**4. Personnel Security**

Google personnel are required to conduct themselves in a
manner consistent with the company’s guidelines regarding
confidentiality, business ethics, appropriate usage, and
professional standards. Google conducts reasonably
appropriate background checks to the extent legally
permissible and in accordance with applicable local labor
law and statutory regulations.

Personnel are required to execute a confidentiality
agreement and must acknowledge receipt of, and compliance
with, Google’s confidentiality and privacy policies.
Personnel are provided with security training. Personnel
handling Customer Data are required to complete additional
requirements appropriate to their role (e.g.
certifications). Google’s personnel will not process
Customer Data without authorization.

**5. Subprocessor Security**

Before onboarding Subprocessors, Google conducts an audit
of the security and privacy practices of Subprocessors to
ensure Subprocessors provide a level of security and
privacy appropriate to their access to data and the scope
of the services they are engaged to provide. Once Google
has assessed the risks presented by the Subprocessor, then
subject to the requirements described in Section 11.3
(Requirements for Subprocessor Engagement) of this
Addendum, the Subprocessor is required to enter into
appropriate security, confidentiality and privacy contract
terms.

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