Adobe
adobe.com
Automated, point-in-time. Not independently reviewed or approved by TRUSTYCYBER unless expressly stated.
- No formal subprocessor register disclosed
- No clear commitment that your data will not train their models
- Data retention window not stated
+1 more
See Before you sign, with what to ask for ↓
Scanned Sep 3, 2026 · Public evidence · Point-in-time
Higher scores indicate stronger, independently supported AI assurance — governance, AI systems, models, data, supply chain and third-party assurance evidence. The score and the decision are related but different: a well-scored vendor can still carry conditions.
Before you sign
Why it matters: The vendor names AI-related providers or partially addresses its supply chain, but the public sources scanned do not include a formal, dated subprocessor register.
What to ask for: Request a dated subprocessor register with change-notification terms for the DPA/order form.
Why it matters: The public sources scanned do not clearly state that customer prompts, files, and outputs are excluded from training or fine-tuning of first- or third-party models.
What to ask for: Get a no-training clause covering first- and third-party models into the DPA/order form.
“Adobe does not analyze your content to train generative AI models, unless you choose to submit content to the Adobe Stock marketplace.”
“Adobe may analyze your content processed or stored on our servers using techniques such as machine learning to improve our products and services. You can opt out of content analysis at any time.”
Why it matters: The public sources scanned do not give a retention period for customer data or prompts/outputs.
What to ask for: Get retention windows, in days, in writing.
“which we retain for ten years after your last interaction with us.”
Why it matters: AI is used but the public sources scanned do not name which foundation models or providers sit in the request path.
What to ask for: Require named providers and model versions, plus notice before any model change.
Buyer questionsanswered only from the public evidence scanned — click a row for the answer
!Will they train on your data?Ask the vendor
Adobe states it does not analyse customer content to train generative AI models, with an explicit carve-out for content the user chooses to submit to the Adobe Stock marketplace.
Requires written confirmation — see Before you sign ↓
“Adobe does not analyze your content to train generative AI models, unless you choose to submit content to the Adobe Stock marketplace.”
“Adobe may analyze your content processed or stored on our servers using techniques such as machine learning to improve our products and services. You can opt out of content analysis at any time.”
!How long do they keep your data?Ask the vendor
Retention is criteria-based: most personal information is kept while the account is active, with contract and transaction records retained for ten years after the last interaction; no content-data retention windows are stated publicly.
Requires written confirmation — see Before you sign ↓
“which we retain for ten years after your last interaction with us.”
!Who else can access your data?Ask the vendor
Adobe publishes an annual transparency report, states it has built no government backdoors, challenges permanent gag orders in court, and seeks to redirect requests for enterprise customer data to the enterprise itself.
Requires written confirmation — see Before you sign ↓
“In the rare instance where Adobe receives a request targeting disclosure of enterprise customer data, consistent with U.S. Department of Justice policy , Adobe always seeks to redirect the Government to obtain the data directly from the enterprise.”
“providers of artificial intelligence technologies that record and analyze your content or communications,”
!Where is your data processed?Ask the vendor
Adobe discloses the US and India as main processing locations, with transfers to all countries where Adobe, its affiliates, providers and partners operate, under the EU-US, UK and Swiss Data Privacy Frameworks and data transfer agreements.
Confirm in writing: Ask the vendor to state this in writing before signing.
“The main locations where we process your personal information are the US and India, but we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate.”
“Adobe complies with the EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework.”
!What happens in a security incident?Ask the vendor
Adobe operates an RFC 9116 security.txt routing to a HackerOne programme and a PSIRT contact with PGP key, alongside regularly published security bulletins and advisories.
Confirm in writing: Ask the vendor to state this in writing before signing.
“Contact: https://hackerone.com/adobe”
Key findingsclick a row for the evidence
✓Certification breadth with AI services named in scopeStrong
A per-service compliance list carries SOC 2 Type 2, the ISO 27001 family, ISO 22301, FedRAMP, CSA STAR Level 2, C5, ISMAP and scoped IRAP - and its scope footnotes explicitly place Adobe Firefly and Acrobat AI Assistant inside certified service groupings, with scope limits footnoted rather than glossed.
Most vendors publish certification logos without saying which products they cover; a list that names the AI services in scope and footnotes what is excluded is materially more usable for due diligence.
“[2] Adobe Creative Cloud for enterprise includes Adobe Admin Console, Adobe Behance, Adobe Cloud Platform and Collaboration (Enterprise Storage Management), Adobe Developer Platform, Adobe Express, Adobe Firefly, Adobe Fonts, Adobe Frame.io, Adobe InDesign, Adobe Lightroom, Adobe Photoshop, Adobe Sensei, Adobe Stock, Adobe Substance 3D, and Adobe XD, as well as identity, licensing and entitlement, and other supporting services.”
“Adobe Document Cloud - Acrobat Web, Acrobat Services (PDF Services API), and Acrobat AI Assistant”
“All these attestations have been certified by third-party auditors.”
✓A clear generative-AI training commitment with one carve-outStrong
Adobe commits not to analyse customer content to train generative AI models, excepting content submitted to the Adobe Stock marketplace, and separately offers an opt-out for machine-learning content analysis used for product improvement.
The commitment is specific about the carve-out rather than absolute-sounding, which makes it credible, but the Stock exception and the analysis/training distinction both belong in writing for any contract.
Question for vendor: Confirm in writing that no content from the organisation's licensed services is used to train generative AI models, and how the Adobe Stock carve-out is prevented from applying to enterprise content.
“Adobe does not analyze your content to train generative AI models, unless you choose to submit content to the Adobe Stock marketplace.”
“Adobe may analyze your content processed or stored on our servers using techniques such as machine learning to improve our products and services. You can opt out of content analysis at any time.”
!Model providers and subprocessors are not named publiclyGap
No collected page names the foundation models behind Firefly or the AI Assistants, whether any third-party model providers sit in the processing path, or the subprocessors behind Adobe services - AI-technology processors are disclosed only as a category, and hosting providers only as leading cloud providers.
A buyer cannot establish from public evidence whose models process their content or where the contractual protections run; this is the largest gap in an otherwise strong disclosure surface.
Question for vendor: Name the model providers and subprocessors in the processing path for the AI features in scope, and provide the subprocessor register with change-notification terms.
“providers of artificial intelligence technologies that record and analyze your content or communications,”
“Adobe solutions are hosted in the data centers of leading cloud hosting providers worldwide.”
!No public AI-specific testing or evaluation disclosureGap
Testing evidence on the collected surface is software-security level (Secure Product Lifecycle, bulletins); nothing describes how generative AI features are evaluated or red-teamed before or after release.
For a portfolio shipping generative and agentic AI at this scale, the absence of published model-evaluation practice leaves a domain a buyer must probe directly.
Question for vendor: Describe the evaluation and red-teaming applied to generative AI features before release, and any ongoing monitoring for harmful outputs.
“we build in security using the Adobe Secure Product Lifecycle”
!Incident-response commitments are not quantified publiclyGap
Vulnerability intake and bulletins are strong, but no collected page states a customer breach-notification commitment or timeframe; retention is criteria-based with a ten-year record-retention outer bound and no content-data windows.
Breach-notification SLAs and retention windows are contract-schedule material; their absence from the public surface means they must be confirmed in the DPA before signature.
Question for vendor: State the contractual breach-notification timeframe and the retention and deletion windows for customer content, including on termination.
“Contact: https://hackerone.com/adobe”
“which we retain for ten years after your last interaction with us.”
?Technical dependency observed: GoogleObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Google as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Google appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“providers of artificial intelligence technologies that record and analyze your content or communications,”
“Adobe solutions are hosted in the data centers of leading cloud hosting providers worldwide.”
?Technical dependency observed: StripeObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Stripe as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Stripe appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“providers of artificial intelligence technologies that record and analyze your content or communications,”
“Adobe solutions are hosted in the data centers of leading cloud hosting providers worldwide.”
?Technical dependency observed: AtlassianObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Atlassian as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Atlassian appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“providers of artificial intelligence technologies that record and analyze your content or communications,”
“Adobe solutions are hosted in the data centers of leading cloud hosting providers worldwide.”
Assurance dimensionsweighted components of one score — not eight separate ratings
Organisation & AI governance15% of the score60
Who owns AI risk — policies, responsible-AI principles, human oversight and administrative controls.
Assessed against ISO 42001 · NIST AI RMF · AIUC-1
“These policies also inform our Generative AI Guidelines that apply to Adobe Firefly.”
“The Common Controls Framework (CCF) by Adobe is a set of security activities and compliance controls we implement within our product operations teams as well as various parts of our infrastructure and application teams.”
Governance & accountability: vendor-evidenced, not yet independently corroborated.
AI system15% of the score47
What AI the vendor actually runs and where it sits in the product — the map everything else is judged against.
Assessed against ISO 42001 · NIST AI RMF
“Firefly Services includes Firefly APIs, Lightroom APIs, Photoshop APIs, and Content Tagging APIs.”
How AI features are evaluated before and after release — evals, red-teaming, monitoring.
Assessed against NIST GenAI · NIST AI RMF · ISO 42001
“we build in security using the Adobe Secure Product Lifecycle”
How changes to models and AI features are controlled and communicated — versioning, notice, rollback.
Assessed against ISO 27001 · ISO 42001
“Review current security bulletins and advisories for our products.”
AI system description: vendor-evidenced, not yet independently corroborated.
Model10% of the score0
Which model providers and versions process customer data, and how changes to them are disclosed.
Assessed against NIST GenAI · ISO 42001
Model provider transparency: not publicly evidenced.
Customer data15% of the score77
Whether customer data trains models, how long it is retained, where it is processed, and how it is protected.
Assessed against ISO 27018 · OAIC APPs · EU AI Act
“Adobe does not analyze your content to train generative AI models, unless you choose to submit content to the Adobe Stock marketplace.”
“Adobe may analyze your content processed or stored on our servers using techniques such as machine learning to improve our products and services. You can opt out of content analysis at any time.”
“The main locations where we process your personal information are the US and India, but we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate.”
“which we retain for ten years after your last interaction with us.”
Customer data treatment: the certifications above are independently corroborated, but they cover the management system — these specific disclosures are the vendor's own statements, not yet independently verified.
AI supply chain10% of the score40
The named chain of AI and infrastructure providers behind the product, and how it is disclosed.
Assessed against ISO 27001 · ISO 27017
“providers of artificial intelligence technologies that record and analyze your content or communications,”
“Adobe solutions are hosted in the data centers of leading cloud hosting providers worldwide.”
Security foundation15% of the score85
How security problems are found, reported and handled — disclosure channels, bug bounty, incident response.
Assessed against ISO 27001 · NIST AI RMF
“Contact: https://hackerone.com/adobe”
Vulnerability & incident handling: the certifications above are independently corroborated, but they cover the management system — these specific disclosures are the vendor's own statements, not yet independently verified.
Independent assurance evidence10% of the score63
Whether claimed certifications and attestations are independently corroborated — checked against official registries and issuing bodies. Which certifications, and what each one does and does not establish, is stated per certificate.
Assessed against ISO 17021-1 · ISO 42006 · ISO 27006-1 · ISO 27008
“[2] Adobe Creative Cloud for enterprise includes Adobe Admin Console, Adobe Behance, Adobe Cloud Platform and Collaboration (Enterprise Storage Management), Adobe Developer Platform, Adobe Express, Adobe Firefly, Adobe Fonts, Adobe Frame.io, Adobe InDesign, Adobe Lightroom, Adobe Photoshop, Adobe Sensei, Adobe Stock, Adobe Substance 3D, and Adobe XD, as well as identity, licensing and entitlement, and other supporting services.”
“Adobe Document Cloud - Acrobat Web, Acrobat Services (PDF Services API), and Acrobat AI Assistant”
“All these attestations have been certified by third-party auditors.”
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
None of the corroborated certifications is AI-specific (ISO/IEC 42001 or AIUC-class) — this assurance is security and data-transfer attestation, not AI-management-system assurance.
Legal & contractual10% of the score60
The contractual backbone a buyer can rely on — terms, DPAs, privacy commitments and regulatory posture.
Assessed against EU AI Act · OAIC APPs
“In the rare instance where Adobe receives a request targeting disclosure of enterprise customer data, consistent with U.S. Department of Justice policy , Adobe always seeks to redirect the Government to obtain the data directly from the enterprise.”
“Adobe complies with the EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework.”
“In contrast, Adobe is considered the “data processor” and not the data controller when enterprise customers such as businesses or educational institutions, use Adobe products and services (e.g., Adobe Experience Cloud) to support their own provision of products and services to individuals”
Legal & contractual transparency: vendor-evidenced, not yet independently corroborated.
Not graded: Agent — not applicable to this scan.
What would strengthen assuranceeach figure is from today's score — resolving one changes the others
Resolving an evidence gap strengthens the dimension it belongs to, and with it the score: 63 → up to 82 with every identified gap resolved.
AI supply chainclick a node to focus it · drag to pan · zoom with the controls
What you inheritTrustyCyber's AI Shared Responsibility Matrix v1.0
This scan names the vendor’s AI supply chain without assessing the responsibility split — that depends on how you consume the product. Under the common managed models, a deployer inherits 16 of the matrix’s 41 responsibilities from providers, each with named evidence owed.
Map your inherited responsibilitiesAssurance evidence: certifications 18 — registry checks and verification ladders, click to view
Claimed for Creative Cloud for enterprise (incl. Firefly), Document Cloud groupings (incl. Acrobat AI Assistant), Experience Cloud, Managed Services and Commerce on Cloud, per Adobe's compliance list (Security, Availability & Confidentiality; Commerce adds HIPAA).
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Claimed alongside SOC 2 for the Creative Cloud, Document Cloud and Experience Cloud service groupings.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Claimed for Creative Cloud for enterprise (incl. Firefly), Document Cloud groupings (incl. Acrobat AI Assistant), Experience Cloud and Managed Services.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Claimed for the same service groupings as ISO 27001.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Claimed for the same service groupings as ISO 27001.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Business-continuity certification claimed for the Creative Cloud, Document Cloud and Experience Cloud groupings.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Quality-management certification claimed for the major cloud service groupings.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
FedRAMP Tailored claimed for Creative Cloud for enterprise, Document Cloud groupings and Experience Cloud (footnoted to Analytics and Campaign only); FedRAMP Moderate for Acrobat Sign for Government and AEM/Connect Gov Cloud.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Claimed for Creative Cloud for enterprise, Document Cloud groupings, Experience Cloud and Managed Services.
Checked against CSA STAR Registry, Sep 3, 2026: Verified on the registry
Germany C5 claimed for Acrobat Sign Solutions and the Acrobat Web/Services/AI Assistant grouping.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Assessed at Protected level, footnote-scoped to Customer Journey Analytics Australia, Acrobat Sign Australia and AEM Gov Cloud Australia only.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Japan ISMAP registration claimed for Acrobat Sign Solutions and the Acrobat Web/Services/AI Assistant grouping.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Compliant service provider claimed for Acrobat Sign Solutions, Commerce on Cloud and Managed Services (enhanced security offering); merchant for Adobe.com eCommerce.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Registered, footnote-scoped to Adobe's San Jose and Dublin office locations only.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Adobe-wide security claim on the compliance list; scope beyond Level 1 not stated.
Not yet checked against a registry — a verification task is queued with TrustyCyber.
Not claimed in any public source scanned. This is the AI-management-system certification — in its absence, the vendor’s AI governance rests on its general security and privacy certifications.
Checked against Data Privacy Framework (dataprivacyframework.gov), Sep 3, 2026: Verified on the registry
Checked against FedRAMP Marketplace (fedramp.gov), Sep 3, 2026: Verified on the registry
Sources 28 — click to view
Appendix: standards landscape 8 — click to view
Where each standard behind this assessment stands today, from TrustyCyber’s continuously maintained standards radar.
Want to go further?
This scan assesses Adobe at an organisational level. Assurance can vary significantly between products, models and agents — enter the product you’re evaluating to run a deeper AI System Assurance Scan.
Scan a specific product →This automated result is based on publicly available information at the time of scanning. It is not an audit, certification, legal opinion or assurance engagement. Publicly unavailable evidence may materially change the conclusion.
