Does Amazon CloudFront require disclosure in a privacy policy?

Yes. Because CloudFront processes visitor data including IP addresses and request headers as a sub-processor under the AWS Data Processing Addendum, you must disclose its use in your privacy policy. This is required under GDPR Article 28 and CCPA regulations governing data processors. Failure to disclose sub-processors can result in regulatory penalties.

What specific data does Amazon CloudFront collect?

CloudFront collects IP addresses for content routing and request headers (such as User-Agent and Referer) to optimize delivery. CloudFront may also log information about requested resources and response codes. AWS retains access logs that include visitor IP addresses and timestamp data when logging is enabled on your distribution.

Does Amazon CloudFront require a cookie consent banner?

No. CloudFront itself does not set cookies by default. However, if you enable CloudFront cookies for caching or forwarding purposes, or if your origin server sets cookies, you must disclose those separately. Always review your specific CloudFront configuration and origin server behavior.

Who processes the data and where is it transferred?

Amazon Web Services, Inc. (United States) operates and processes CloudFront data. Data is transferred to and processed in the United States and may be replicated across AWS global infrastructure. AWS has committed to Standard Contractual Clauses and other mechanisms to ensure adequate protection under GDPR and similar regulations.

Infrastructure

Privacy policy clauses for Amazon CloudFront

Amazon CloudFront is a content delivery network (CDN) operated by Amazon Web Services that caches and distributes website content globally from servers located near end users. Websites use CloudFront to improve page load speed, reduce bandwidth costs, and enhance performance for geographically dispersed audiences.

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What data Amazon CloudFront collects

Your privacy policy must disclose each of the following data types when you use Amazon CloudFront.

IP address (for CDN routing)

Request headers

When does Amazon CloudFront trigger privacy obligations?

Data Flow Activation

The moment you deploy Amazon CloudFront as your CDN, your origin server's traffic is routed through AWS infrastructure globally. CloudFront immediately begins collecting and processing:

–Client IP addresses — logged for every request to determine optimal edge location routing
–Request headers — including User-Agent, Referer, and custom headers, which may contain personal data depending on your application logic

These data flows are automatic and occur before any user consent mechanism can execute.

Regulatory Triggers

GDPR (applies if any visitor is in the EU): IP addresses qualify as personal data under GDPR recital 30. Once CloudFront processes them, you have a controller-processor relationship requiring a Data Processing Agreement (DPA) under GDPR Article 28. AWS provides a Data Processing Addendum; you must execute it before CloudFront processes any EU resident data.

Common compliance pitfalls

Pitfall 1: No Executed DPA with AWS

The mistake: Deploying CloudFront without signing AWS's Data Processing Addendum, assuming GDPR compliance happens by default.

Why it happens: Infrastructure teams deploy CloudFront for performance without consulting compliance or legal. The DPA requirement feels like a "legal checkbox" rather than a prerequisite.

Consequence: Without an executed DPA, you are processing EU resident data without a lawful basis under GDPR Article 6. AWS is processing data on your behalf without a valid Article 28 contract. Regulators (EDPB, national DPAs) have consistently held that controller-processor relationships *without* a DPA constitute a serious breach. Fines under GDPR Article 83(4) can reach 4% of global revenue. Additionally, you have no contractual indemnity if AWS suffers a breach affecting your users.

Pitfall 2: IP Address Not Disclosed in Privacy Policy

The mistake: Listing "cookies" and "analytics providers" in your privacy policy but omitting that CloudFront collects and processes IP addresses globally.

Why it happens: CloudFront is infrastructure, not a "service" operators think of as a data processor. Many assume privacy disclosures only need to cover first-party analytics or advertising tags.

Consequence: Under GDPR Article 13 (pre-contract) and Article 14 (for indirect collection), you must disclose all processors and data flows. Omitting CloudFront's IP logging means your privacy notice is materially incomplete. If a regulator audits and finds a hidden processor, it demonstrates intentional non-transparency and increases enforcement severity. CCPA Section 1798.100 requires equally specific disclosure of the categories of service providers handling personal information.

Pitfall 3: Misconfiguring CloudFront Logs and Retention

The mistake: Enabling CloudFront access logs (which include full request data, headers, and IP addresses) and storing them indefinitely without retention policies or access controls.

Why it happens: Logs are useful for debugging and analytics. Teams enable them for troubleshooting but forget they are personal data subject to the same GDPR Article 5 storage limitation and data minimization principles as any other personal data store.

Consequence: Indefinite log retention violates GDPR Article 5(1)(e) — data must not be kept longer than necessary. If you cannot articulate a legal basis for retaining 12 months of IP address logs, you are storing personal data unlawfully. Subject Access Requests (SARs) under GDPR Article 15 then force you to retrieve and provide unstructured log data, creating operational burden and breach risk. CCPA similarly requires you to be able to identify what personal information is stored and delete it upon request.

Privacy policy clauses for Amazon CloudFront

What data Amazon CloudFront collects

When does Amazon CloudFront trigger privacy obligations?

Data Flow Activation

Regulatory Triggers

Why This Matters for Small Teams

Where data goes

Common compliance pitfalls

Pitfall 1: No Executed DPA with AWS

Pitfall 2: IP Address Not Disclosed in Privacy Policy

Pitfall 3: Misconfiguring CloudFront Logs and Retention

Legal note

Sample privacy policy clause

What regulators look for

Priority Areas in DPA Audits

Frequently asked questions

Does Amazon CloudFront require disclosure in a privacy policy?

What specific data does Amazon CloudFront collect?

Does Amazon CloudFront require a cookie consent banner?

Who processes the data and where is it transferred?

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