Does Zoom need to be considered as a processor

Whenever a call on Zoom is initiated, Zoom Video Communications, Inc. processes personal data. Mp4 of all video, audio, whiteboard, captions and presentations, audio transcript files, attendee information (screen name, join/leave time), etc, they are all personal data according to the definition of personal data that can be found in Article 4 (1) GDPR: “any information relating to an identified or identifiable natural person”. Zoom Video Communications, Inc. processes personal data on behalf of its customers and acts as a Data Processor according to the definition from Article 4 (8). Since Zoom Video Communications, Inc is a US-based company, the new EU Standard Contractual Clauses should be signed. Zoom Video Communications, Inc, offers a Data Processing Agreement which also includes EU Standard Contractual Clauses requirements, at https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf

You can find more details at these links:

• Article 4 GDPR, Definitions: https://advisera.com/gdpr/definitions/
• Chapter V GDPR, Transfers of personal data to third countries or international organisations: https://advisera.com/eugdpracademy/gdpr-text/transfers-of-personal-data-to-third-countries-or-international-organisations/
• 3 steps for data transfers according to GDPR: https://advisera.com/articles/3-steps-for-data-transfers-according-to-gdpr/