EU Data Act Notice
Data Access and User Rights Information
Effective Date: 12th September 2025
Last Updated: 27th November 2025
What Is Covered By This Notice
In compliance with Regulation (EU) 2023/2854 (the "EU Data Act"), CDW ("CDW," "we," "us," or "our") provides this notice to inform our customers about data rights and responsibilities regarding connected products and data processing services that we resell.
Important: As a technology reseller, our role as a data holder varies depending on the specific products and services provided. This notice explains your rights and our obligations when we act as a data holder and when third-party manufacturers or service providers retain that role.
Our Role and Data Holder Status
When we are NOT the Data Holder: For most connected products and related services we resell, we are not the data holder, and the original equipment manufacturer or service provider retains control over data generation and access. In these cases, you should contact the manufacturer directly for data access requests.
When we are the Data Holder: We act as the data holder only in specific circumstances:
• Where we generate or control the data from connected products we provide; or
• Where we process your data, but you lack the independent technical means to export your data (this includes our provision of proprietary platforms without export functionality or managed services without customer access).
Your Rights When We are the Data Holder:
When we act as the data holder, you have the following rights:
• Data Access Right: You may request and will be granted access to eligible data in accordance with the Data Act. Data access will be provided without undue delay and within the timeframes specified in our EU Data Act Addendum.
• Third-Party Data Sharing: You may authorise a third party recipient to receive eligible data without charge, subject to appropriate written authorisation and legal requirements being met.
• Service Switching Rights: We will assist with switching to alternative providers where we provide data processing services and control access to such data.
Data Processing Services – Customer Controlled vs. Seller Controlled
Customer Controlled Services: Where you process data through our services but retain direct access and control, you maintain direct access rights to your data without requiring our assistance for data export or switching.
Seller Controlled Services: Where we control data processing and you lack independent export capabilities, we will facilitate your data access and switching rights in accordance with our EU Data Act Addendum.
EU Data Act Addendum
Our comprehensive EU Data Act Addendum supplements all our customer agreements involving connected products or data processing services. Our EU Data Act Addendum is available here and provides detailed procedures, timeframes, and technical requirements for exercising your data rights under the EU Data Act.
How to Contact Us
For Data Access Requests (when CDW is the data holder): Email: legal@uk.cdw.com
Address: CDW Limited, 3rd Floor, One New Change, London EC4M 9AF
Phone: 020 7791 6000
For Third-Party Product Data Requests: Contact your account manager for manufacturer information and product documentation to facilitate your direct contact with the appropriate data holder.
