Clio (Duo / Work)
Data storage 2/3
What the vendor states (our summary):
Hosting choice incl. Europe (AWS EU)
What this means: EU/EEA, or selectable region including Switzerland. Where data rests decides which law and which authorities can reach it. Swiss firms often require Swiss residency for client matters.
Where the AI runs / sub-processors 1/3
What the vendor states (our summary):
AI processed in customer's region per Clio; AI subprocessors AWS Bedrock, OpenAI, Google, Azure (US/EU) but Anthropic listed US-only
What this means: Can leave the region, or relies on US LLM APIs. Storage and AI processing are often in different places. A tool can store data in Zurich and still send prompts to models in another country.
US Cloud Act exposure 1/3 ⚖︎
What the vendor states (our summary):
Canadian vendor; US-parent AI and hosting subprocessors
⚖︎ Judgment call: Non-US vendor but relies on US-parent AI/cloud providers, one listed US-only.
What this means: Non-US vendor on US-parent clouds/models. The US CLOUD Act lets US authorities require US providers to disclose data in their possession, custody or control, wherever it is stored. This score is always an editorial judgment call.
Art. 321 SCC auxiliary terms 2/3
What the vendor states (our summary):
Mutual confidentiality clause (Terms s.4.1); no auxiliary-person (Art. 321 SCC) term found
What this means: General confidentiality claim, no auxiliary-person term. Under Art. 321 SCC, auxiliaries of a lawyer are bound by professional secrecy, and Art. 13 para. 2 BGFA/LLCA makes the lawyer responsible for ensuring they respect it. Written auxiliary terms help document that.
revFADP / GDPR processing agreement 2/3
What the vendor states (our summary):
Themis Data Processing Addendum; GDPR compliance stated
What this means: GDPR DPA or US framework certification only. Art. 9 revFADP and Art. 28 GDPR require a contract (or legal basis) when a processor handles personal data on your behalf.
No training on customer data 2/3
What the vendor states (our summary):
No training of generalised LLMs on confidential information, but Terms allow de-identified, aggregated content and outputs to improve Clio's AI services
What this means: Allows de-identified/usage-based improvement. If customer data trains a model, confidential content could surface elsewhere. Look for a contractual ban that also binds model providers.
ISO 27001 / SOC 2 3/3
What the vendor states (our summary):
Annual SOC 2 Type II and SOC 1 Type II
What this means: Own ISO 27001 or SOC 2 Type II. Independent audits (ISO 27001, SOC 2 Type II) give evidence that security controls exist and are tested.
What to ask this vendor
- Data storage In which country and data centre are our documents, prompts, outputs and backups stored?
- Data storage Can we contractually fix storage in Switzerland?
- Where the AI runs / sub-processors In which countries do the AI models process our prompts, including fallback or peak-load routing?
- Where the AI runs / sub-processors Please provide the full sub-processor list with locations, and how we are notified of changes.
- US Cloud Act exposure Is your company or any sub-processor in the processing chain a US company or a subsidiary of one?
- US Cloud Act exposure How would you respond to a foreign government request for our data, and will you notify us?
- Art. 321 SCC auxiliary terms Will you contractually accept auxiliary-person (Hilfsperson) status under Art. 321 SCC and pass it to sub-processors?
- Art. 321 SCC auxiliary terms Who at your company or at sub-processors can access our content in clear text?
- revFADP / GDPR processing agreement Please send your DPA. Does it reference the Swiss revFADP as well as the GDPR?
- revFADP / GDPR processing agreement Which transfer mechanism covers any processing outside Switzerland/EEA?
- No training on customer data Is it contractually excluded that our data trains or fine-tunes any model, including the model providers’ models?
- No training on customer data What is retained by model providers (abuse monitoring, logs), and for how long?
Informational only, not legal advice. Results reflect vendors’ public statements on the date checked and our scoring rules. Verify contracts yourself before using any tool with client data.