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What does ServiceNow do?

ServiceNow is the leading enterprise SaaS platform for IT Service Management, Employee Experience, Customer Service Management and low code workflow automation. European organisations use ServiceNow portals to publish service catalogues, knowledge base articles, incident reporting forms, HR self-service and digital workflows. When a ServiceNow portal is embedded on a public website or linked from a corporate intranet, it sets first party cookies, sometimes loads analytics scripts (Adobe Analytics, Mixpanel, Pendo) and transfers user data to ServiceNow infrastructure.

What ServiceNow does and how it appears on a website

ServiceNow Inc. is a publicly traded US software company that operates the Now Platform, a low code workflow engine that powers IT Service Management, Employee Experience, Customer Service Management, Field Service, GRC, HR and many vertical solutions. European enterprises use ServiceNow portals as public service catalogues (customer.service-now.com), employee self-service hubs and incident reporting interfaces. The portals are built on top of UI Builder, ServiceNow Service Portal or the newer Workspace experience.

Cookies and data collected by ServiceNow

ServiceNow sets first party cookies on the instance domain such as JSESSIONID, glide_user, glide_session_store and BIGipServer for session management and load balancing. Optional integrations add analytics cookies (Adobe Analytics, Mixpanel, Pendo, Glassbox). For embedded chat widgets and Virtual Agent, ServiceNow may set glide_va_session and other interaction cookies. Personal data collected through the portal flows into the underlying ServiceNow tables.

GDPR and ePrivacy implications

ServiceNow Inc. is processor for the data the customer puts into the platform and controller for its own customer support, sales and product telemetry. The ServiceNow DPA (Customer Data Processing Addendum) incorporates the European Commission Standard Contractual Clauses, lists sub-processors and binds ServiceNow to ISO 27001, ISO 27018, SOC 2, EU Cloud Code of Conduct and FedRAMP for US government workloads. Strictly necessary cookies for session and security are exempt from ePrivacy consent; optional analytics or marketing cookies require opt-in.

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International data transfers and ServiceNow EU Cloud

ServiceNow Inc. is certified under the EU-US Data Privacy Framework. EU customers can choose to host their instance in Ireland, the Netherlands, Germany, the United Kingdom or Switzerland. The ServiceNow EU Cloud, generally available since 2024, contractually keeps customer data and most operational processing inside the EU, with EU based support engineers and EU only sub-processors. Personal data continues to be subject to US extraterritorial laws because the parent company is American.

Consent and legal basis

Contractual necessity (Article 6(1)(b) GDPR) covers most customer and employee portal scenarios where the user has signed up for a service or is acting in an employment relationship. Legitimate interest (Article 6(1)(f)) covers security telemetry and ITSM operations. Consent (Article 6(1)(a)) is required for optional analytics, marketing and Pendo session replay style cookies.

Practical compliance steps

Sign the ServiceNow DPA, opt into ServiceNow EU Cloud if the workload contains EU personal data, restrict instance access through role based controls, configure data retention plug-ins, encrypt sensitive fields with the Edge Encryption add on, list ServiceNow as a processor in the privacy notice, document the transfer impact assessment, and integrate every non strictly necessary cookie of the customer portal into the Consent Management Platform.

GDPR consent category

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Websites using ServiceNow must obtain user consent under GDPR regulations.

Legal basisContractual necessity under Article 6(1)(b) GDPR for employee or customer accounts that use ServiceNow portals. Legitimate interest under Article 6(1)(f) for incident management and security. Consent under Article 6(1)(a) for any optional analytics or marketing cookie added to the customer facing service catalogue or knowledge base.
Risk levelmedium
Applicable regulationsGDPR, ePrivacy Directive, EU-US Data Privacy Framework, German TTDSG / TDDDG, ServiceNow EU Cloud commitments, ISO 27001, SOC 2, FedRAMP for US government customers

DPIA considerations

A DPIA is required when ServiceNow holds employee personal data at scale, customer service records, HR cases or any sensitive workflow data. The DPIA must cover the chosen data centre region, the ServiceNow EU Cloud option, encryption, role based access controls, retention policies, the sub-processor list, and the response plan for US government access requests under the EU-US Data Privacy Framework and FISA 702.

Sample consent text

Our customer portal is powered by ServiceNow. ServiceNow may set technical cookies for session management and, if enabled, analytics cookies through Adobe Analytics or Mixpanel. Some data may transit through ServiceNow infrastructure in the United States under the EU-US Data Privacy Framework and Standard Contractual Clauses. By clicking Accept, you authorise the optional analytics cookies. You can also Reject and only the strictly necessary cookies will be set.

Technical details

Tracking methodEnterprise SaaS platform for IT service management, employee experience and workflow automation. Web portals and customer service catalogues embed first party JavaScript that sets multiple session and analytics cookies on the now.servicenow.com or customer.service-now.com domain.
Server locationServiceNow Inc. operates over 60 data centre pairs across the United States, Canada, Europe (Ireland, Germany, United Kingdom, Netherlands, Switzerland), Asia Pacific and Australia. Customers can pin their instance to specific regions.
Data transferred outside the EUOperated by ServiceNow Inc. (Santa Clara, California, USA), with ServiceNow Nederland B.V. as the EU contracting entity. Transfers to the US rely on the EU-US Data Privacy Framework certification and the ServiceNow Data Processing Addendum based on Standard Contractual Clauses. Optional ServiceNow EU Cloud commits to processing inside the EU.

Third-party domains contacted

service-now.comservicenow.comnow.servicenow.comservicenowservices.com

Cookies placed

NameTypeDurationPurpose
JSESSIONIDHTTP cookieSessionJava EE session cookie used by the ServiceNow application server.
glide_userHTTP cookieSessionIdentifies the logged in ServiceNow user inside an instance.
glide_session_storeHTTP cookieSessionPersists the user session state across instance nodes.
BIGipServerHTTP cookieSessionF5 BIG-IP load balancer cookie used in front of ServiceNow nodes.
glide_va_sessionHTTP cookieSessionVirtual Agent (chat) session state when the chat widget is enabled.

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Frequently asked questions

What cookies does ServiceNow set?

ServiceNow sets first party session cookies on the instance domain: JSESSIONID, glide_user, glide_session_store, BIGipServer for the load balancer and glide_va_session when the Virtual Agent chat is enabled. Optional analytics tools (Adobe Analytics, Mixpanel, Pendo) add their own cookies.

Do I need consent to use ServiceNow?

Session and load balancing cookies are strictly necessary and exempt from consent. Optional analytics or session replay cookies need prior opt-in, channelled through the Consent Management Platform.

What is the legal basis?

Article 6(1)(b) GDPR (contract) for customer or employee portal usage. Article 6(1)(f) for ITSM and security telemetry. Article 6(1)(a) consent for optional analytics, marketing and session replay cookies.

Does ServiceNow transfer data to the US?

By default, EU customers can pin the instance to an EU data centre. The optional ServiceNow EU Cloud keeps customer data and most processing inside the EU. ServiceNow Inc. remains certified under the EU-US Data Privacy Framework and signs Standard Contractual Clauses for any residual transfer.

Do I need a DPIA?

Yes when ServiceNow holds large scale personal data such as employee HR cases, customer service records or whistleblower channels. Document the region choice, EU Cloud option, encryption, retention and the FISA 702 response plan.

How do I implement ServiceNow compliantly?

Sign the ServiceNow DPA, opt into the EU Cloud where applicable, restrict roles and access controls, configure data retention plug-ins, encrypt sensitive fields with Edge Encryption, list ServiceNow in the privacy notice and integrate optional cookies into the CMP.

Are there alternatives to ServiceNow?

For ITSM: Atlassian Jira Service Management, BMC Helix, ManageEngine ServiceDesk Plus, Freshservice. For low code: Microsoft Power Platform, OutSystems, Mendix. For employee experience: SAP SuccessFactors, Workday. EU sovereign alternatives include EasyVista and EFECTE.

How do I update my cookie policy for ServiceNow?

List ServiceNow Inc. and the EU contracting entity ServiceNow Nederland B.V., describe the session and analytics cookies, mention the EU-US Data Privacy Framework, link to the ServiceNow DPA and add an explicit statement about the EU Cloud commitment if applicable.