Does AWS Lambda require disclosure in a privacy policy?

Yes. AWS Lambda processes data on your behalf as a third-party processor, which requires disclosure under GDPR, CCPA, and other privacy regulations. You must inform users that their data may be transmitted to AWS Lambda for processing, and document your data processing agreement with Amazon Web Services Inc.

What specific data does AWS Lambda collect?

AWS Lambda collects function invocation payloads (the data sent to your functions), CloudWatch logs containing function execution details and errors, and request context metadata including timestamps and identifiers. If your functions process user data, that information may be logged and retained in CloudWatch Logs, potentially including personally identifiable information (PII).

Does AWS Lambda require a cookie consent banner?

No. AWS Lambda itself does not use cookies. However, if your website uses cookies alongside Lambda functions, you must disclose all cookie usage separately. Review your implementation to identify whether any cookies are present before concluding that a banner is unnecessary.

Who processes data in AWS Lambda and where is it transferred?

Amazon Web Services Inc., headquartered in the United States, processes data as your service provider. Data is transferred to AWS and stored in your selected region (Lambda supports multiple geographic locations). AWS is SOC 2, HIPAA, and ISO 27001 certified, and you should establish a Data Processing Agreement compliant with GDPR Standard Contractual Clauses if transferring EU residents' data.

Cloud & Backend

Privacy policy clauses for AWS Lambda

AWS Lambda is a serverless compute service that executes application code in response to events without requiring server management. Websites use Lambda to run backend functions, process data, and handle automated tasks while paying only for actual execution time.

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What data AWS Lambda collects

Your privacy policy must disclose each of the following data types when you use AWS Lambda.

Function invocation payloads

CloudWatch logs (may contain PII)

Request context and metadata

When does AWS Lambda trigger privacy obligations?

Data flows that trigger obligations

AWS Lambda begins processing data the moment a function executes. Every invocation sends the request payload, headers, and context metadata to AWS servers in your chosen region. If your function logs anything—errors, user IDs, request details—CloudWatch captures and stores that data by default. This happens immediately and automatically; there is no "opt-in" moment.

Which regulations apply

GDPR (if you have EU users): AWS Lambda triggers Article 6 (lawful basis) and Article 28 (processor obligations) requirements immediately. You must have a Data Processing Agreement (DPA) with AWS before any function runs. Article 5(1)(a) requires explicit legal ground for processing; Article 5(1)(f) requires security safeguards—AWS's certifications (SOC 2, ISO 27001) help satisfy this, but you remain accountable.

CCPA (California residents): If you collect personal information via Lambda functions (IP addresses, user IDs in logs, request metadata), CCPA Section 1798.100 gives users right-to-know obligations. You must disclose what data is collected.

Common compliance pitfalls

Pitfall 1: CloudWatch logs leaking PII without disclosure or retention policy

Lambda functions log to CloudWatch by default. Developers often log request bodies, query parameters, or error details that contain personally identifiable information—email addresses, phone numbers, API keys, session tokens. These logs are retained indefinitely unless you explicitly set a retention policy (1 day to 10 years). The compliance mistake: you've disclosed "we use AWS Lambda" but not that "CloudWatch logs may contain customer email addresses and are retained for [X] days." GDPR Article 5(1)(e) requires storage limitation; CCPA Section 1798.100 requires you disclose what personal information is collected. Regulators flagging this first during audits. The consequence: either a fine for undisclosed processing, or forced deletion of logs containing personal data, disrupting audits you may need for incident response.

Pitfall 2: Missing or stale Data Processing Agreement with AWS

You've deployed Lambda but your DPA with AWS is unsigned, outdated, or missing standard clauses (Sub-processors, data subject rights, security obligations). GDPR Article 28(3) explicitly requires a written contract covering processor responsibilities. Many indie founders assume AWS's standard Terms of Service suffice—they do not. AWS provides a model DPA, but you must actively accept it. Consequence: non-compliance with GDPR Article 28, exposing you to regulatory action and liability claims from data subjects. Your data processing is technically unlawful under GDPR until the DPA is executed.

Pitfall 3: Not declaring data residency or cross-border transfers

Lambda functions can run in any AWS region (us-east-1, eu-west-1, ap-southeast-1, etc.). If you select a region outside the EU but process EU resident data, you trigger GDPR Chapter V (data transfer) requirements. You must implement Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms. Many founders leave Lambda in the default us-east-1 region without realizing data is leaving the EU. Post-Schrems II, this is actively enforced. Consequence: supervisory authority fine and order to stop processing or implement compliant transfer mechanisms retroactively.

Privacy policy clauses for AWS Lambda

What data AWS Lambda collects

When does AWS Lambda trigger privacy obligations?

Data flows that trigger obligations

Which regulations apply

First concrete step

Where data goes

Common compliance pitfalls

Pitfall 1: CloudWatch logs leaking PII without disclosure or retention policy

Pitfall 2: Missing or stale Data Processing Agreement with AWS

Pitfall 3: Not declaring data residency or cross-border transfers

Legal note

Sample privacy policy clause

What regulators look for

Audit priorities

Frequently asked questions

Does AWS Lambda require disclosure in a privacy policy?

What specific data does AWS Lambda collect?

Does AWS Lambda require a cookie consent banner?

Who processes data in AWS Lambda and where is it transferred?

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