SecurityNordPass and the GDPR: agreement, role and data location.
NordPass is a security tool. Most customers use it as a processor, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Security
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does NordPass do with personal data?
Manage team credentials and protect access to business systems. That is how Privacyboard describes a typical use of NordPass, as a starting point you can edit.
The data usually involved: team member names, email addresses, access logs and information stored in the credential vault.
Is NordPass a processor or a controller?
Most customers use NordPass as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for security 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 NordPass store personal data?
NordPass does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to NordPass?
For the usual use of NordPass, companies most often rely on legitimate interests (GDPR Article 6(1)). Credential and access protection is needed to keep personal data secure (Article 32).
The interest you would state: “Protecting access to our systems and data.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does NordPass have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. NordPass 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.
What we noted when we opened the page: NordPass Business Data Processing Agreement, effective 27 Oct 2025, integral to the Nord Services General Terms; no legal entity named. Servers in different places around the world; EU SCCs (Module 2, Dutch law) and UK Addendum.
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 NordPass agreementHow to declare NordPass
- 1
In your privacy policy
Name NordPass as a recipient, say what it is used for (manage team credentials and protect access to business systems) 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 NordPass 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 NordPass 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 NordPass
- Review who has admin access and how departures are handled.
- Check how long access logs are kept.
- Record the provider as a recipient of staff details.
- Confirm where encrypted data is stored.
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Questions, answered.
Is NordPass GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how NordPass 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 NordPass have a DPA?
Yes. NordPass 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://business.nordsec.com/legal/data-processing-agreement.
Is NordPass a data processor?
Usually, yes. Most customers use NordPass as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use NordPass?
For the usual use of NordPass, companies most often rely on legitimate interests (GDPR Article 6(1)). Credential and access protection is needed to keep personal data secure (Article 32). The interest you would state: “Protecting access to our systems and data.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does NordPass store data?
NordPass does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention NordPass in my privacy policy?
Yes, if NordPass 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 NordPass to my vendor list?
In Privacyboard, pick NordPass 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.
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Privacyboard is not affiliated with NordPass. 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.