Glossary/Privacy and identity/Data processing agreement (DPA)

What is a DPA (data processing agreement) under GDPR?

What a data processing agreement is, what GDPR requires it to include, and when publishers need one with data partners and advertisers.

Written by Samhub with the help of AI·Updated 13 Oct 2026·3 min read
Definition

A data processing agreement (DPA) is the contract GDPR requires when one company (the processor) handles personal data on behalf of another (the controller). It is set out in GDPR article 28.

What a DPA must include

01

Subject and duration

What data is processed, about whom, and for how long.

02

Instructions

The processor acts only on the controller’s documented instructions.

03

Security

The technical and organizational measures that protect the data.

04

Sub-processors

Who else may handle the data, and on what terms.

05

Help and deletion

Support with readers’ rights, and deletion or return of data at the end.

When publishers need a DPA

Every vendor that processes reader data on your behalf needs one: analytics, data platforms, email tools and consent tools. Joint controllers, such as some ad tech partners, need a different agreement under article 26.

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Frequently asked questions

Yes, whenever a processor handles personal data for a controller under GDPR.

The controller decides why and how data is used. The processor handles it on the controller’s instructions.

Yes. It can be a section of the contract or a separate document, as long as it covers what article 28 requires.

Only if they process personal data on your behalf. Sharing ID-free audiences usually does not make them your processor.

Related terms

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