Consent managementTrustArc and the GDPR: agreement, role and data location.
TrustArc is a consent management tool. Most customers use it as a processor, it explains how to get 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
- Consent management
- Usual role
- Usually a processor
- Data location
- Often United States or Germany (EU), check your account
- Agreement
- Obtained through the vendor
What does TrustArc do with personal data?
Show cookie notices, record visitors’ consent choices and manage privacy documents. That is how Privacyboard describes a typical use of TrustArc, as a starting point you can edit.
The data usually involved: visitor consent choices, consent identifiers, IP address and device details, and the pages where consent was given.
Is TrustArc a processor or a controller?
Most customers use TrustArc as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for consent management 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 TrustArc store personal data?
TrustArc is usually associated with United States or Germany (EU), but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account.
What TrustArc says (read on 2026-11-05): Platform hosted on AWS US East-1 (N. Virginia) or EU Central-1 (Frankfurt) Source: https://trust.trustarc.com/en-US/policies/sub-processors-and-affiliates
How to find yours: Check your account settings or the provider’s data processing terms.
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.
Which legal basis usually applies to TrustArc?
For the usual use of TrustArc, companies most often rely on legal obligation (GDPR Article 6(1)). Asking for consent before using cookies, and being able to show it was given, are required by law (GDPR Article 7(1) and the ePrivacy rules).
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, CNIL: cookies and other trackers, questions and answers
Does TrustArc have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
TrustArc does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: TrustArc trust center policies page lists a Data Processing Addendum with a schedule on the Standard Contractual Clauses; full text not readable. Sub-processor page says the platform runs on AWS US East-1 or EU Central-1.
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.
Open the TrustArc reference pageHow to declare TrustArc
- 1
In your privacy policy
Name TrustArc as a recipient, say what it is used for (show cookie notices, record visitors’ consent choices and manage privacy documents) 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 TrustArc 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 TrustArc 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 TrustArc
- Check that the banner blocks non-essential tags until the visitor agrees.
- Keep consent records for as long as you may need to prove them, and no longer.
- Link your privacy policy and cookie list from the banner.
- Test the banner after any change to your site or tools.
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Questions, answered.
Is TrustArc GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how TrustArc is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does TrustArc have a DPA?
TrustArc does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://trust.trustarc.com/policies.
Is TrustArc a data processor?
Usually, yes. Most customers use TrustArc 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 TrustArc?
For the usual use of TrustArc, companies most often rely on legal obligation (GDPR Article 6(1)). Asking for consent before using cookies, and being able to show it was given, are required by law (GDPR Article 7(1) and the ePrivacy rules). This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does TrustArc store data?
TrustArc is usually associated with United States or Germany (EU), but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account. What TrustArc says (read on 2026-11-05): Platform hosted on AWS US East-1 (N. Virginia) or EU Central-1 (Frankfurt) Source: https://trust.trustarc.com/en-US/policies/sub-processors-and-affiliates
Do I need to mention TrustArc in my privacy policy?
Yes, if TrustArc 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 TrustArc to my vendor list?
In Privacyboard, pick TrustArc 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 TrustArc. 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.