SecurityProton Pass and the GDPR: agreement, role and data location.
Proton Pass 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 Proton Pass do with personal data?
Manage team credentials and protect access to business systems. That is how Privacyboard describes a typical use of Proton Pass, 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 Proton Pass a processor or a controller?
Most customers use Proton Pass 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 Proton Pass store personal data?
Proton Pass 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 or Proton Pass’s data processing terms for where your data is stored.
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.
Does Proton Pass have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Proton Pass 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: Proton Data Processing Agreement, last modified 10 Feb 2026, covering Proton services for business customers. Processor is Proton AG (Switzerland); governed by Swiss law. Says transfers go to Switzerland, the EU or adequate countries where possible; no fixed hosting location stated.
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 Proton Pass agreementHow to declare Proton Pass
- 1
In your privacy policy
Name Proton Pass 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 Proton Pass 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 Proton Pass 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 Proton Pass
- 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.
Questions, answered.
Is Proton Pass GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Proton Pass 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 Proton Pass have a DPA?
Yes. Proton Pass 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://proton.me/legal/dpa.
Is Proton Pass a data processor?
Usually, yes. Most customers use Proton Pass 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 Proton Pass store data?
Proton Pass 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 or Proton Pass’s data processing terms for where your data is stored.
Do I need to mention Proton Pass in my privacy policy?
Yes, if Proton Pass 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 Proton Pass to my vendor list?
In Privacyboard, pick Proton Pass 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 Proton Pass. 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.