AuthenticationClerk and the GDPR: agreement, role and data location.
Clerk is a authentication tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in the United States. Below: what to check and how to declare it.
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In short
- Category
- Authentication
- Usual role
- Usually a processor
- Data location
- Usually the United States
- Agreement
- Published by the vendor
What does Clerk do with personal data?
Authenticate users and manage application sessions and access. That is how Privacyboard describes a typical use of Clerk, as a starting point you can edit.
The data usually involved: names, email addresses, user identifiers, IP addresses and authentication logs.
Is Clerk a processor or a controller?
Most customers use Clerk as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for authentication tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Clerk store personal data?
Clerk usually keeps data in the United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs.
How to find yours: Clerk’s documentation describes data storage.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Does Clerk have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Clerk publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the Clerk agreementHow to declare Clerk
- 1
In your privacy policy
Name Clerk as a recipient, say what it is used for (authenticate users and manage application sessions and access) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Clerk with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Clerk to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Clerk
- Confirm where user records are stored and whether you can choose the region.
- Check how long sign-in logs are kept and how users are deleted.
- Keep the provider in your privacy policy as a recipient of account data.
- Review the provider’s security documentation for the controls you rely on.
Questions, answered.
Is Clerk GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Clerk is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Clerk have a DPA?
Yes. Clerk publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://clerk.com/legal/dpa.
Is Clerk a data processor?
Usually, yes. Most customers use Clerk as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does Clerk store data?
Clerk usually keeps data in the United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs. How to find yours: Clerk’s documentation describes data storage.
Do I need to mention Clerk in my privacy policy?
Yes, if Clerk handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Clerk to my vendor list?
In Privacyboard, pick Clerk from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Privacyboard is not affiliated with Clerk. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.