diff --git a/community-lead/user-policy/index.md b/community-lead/user-policy/index.md
index fdfb044..0cdb05e 100644
--- a/community-lead/user-policy/index.md
+++ b/community-lead/user-policy/index.md
@@ -7,4 +7,5 @@ These describe the expectations and rules around the service.
 code-of-conduct
 acceptable-use
 privacy
+sub-processors
 ```
diff --git a/community-lead/user-policy/sub-processors.md b/community-lead/user-policy/sub-processors.md
new file mode 100644
index 0000000..2129519
--- /dev/null
+++ b/community-lead/user-policy/sub-processors.md
@@ -0,0 +1,65 @@
+# Sub-processors
+
+A **sub-processor** is a third-party service that processes data on behalf of 2i2c while we operate infrastructure for a community.
+This page describes the sub-processors used in a typical hub deployment and the kinds of personal data each one handles.
+The specifics differ per hub (e.g., the cloud region where data is stored, or any add-on services), so the list below is not exhaustive.
+See [](#data-processor:find) below to determine the list for a particular hub.
+
+:::{admonition} This is not a legal document
+:class: warning
+This document is provided to set expectations and understanding about 2i2c's cloud infrastructure service.
+It is not legally binding.
+:::
+
+## Typical sub-processors
+
+The services below are common touchpoints for user data (e.g., their identity, files they create, etc).
+
+### Cloud or infrastructure provider
+
+An infrastructure provider (like a cloud provider) hosts the core infrastructure that runs the hub. This includes **compute**, **storage**, and **logging**.
+The cloud region is configured per hub and determines where this data is stored.
+2i2c either manages its own cloud provider account, or uses one managed by the community.
+
+Personal data processed by this sub-processor:
+
+- User home directory contents (e.g., notebooks, data files created during use)
+- The JupyterHub username / authentication database
+- System and access logs
+
+Here are a few common cloud providers we use and their sub-processors pages:
+
+- **Amazon Web Services (AWS)**. [GDPR Center](https://aws.amazon.com/compliance/gdpr-center/), [sub-processors](https://aws.amazon.com/compliance/sub-processors/)
+- **Google Cloud Platform (GCP)**. [GDPR resource center](https://cloud.google.com/privacy/gdpr), [sub-processors](https://cloud.google.com/terms/subprocessors)
+- **Microsoft Azure**. [Data Protection Addendum](https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), [service trust page](https://servicetrust.microsoft.com)
+
+### Identity provider
+
+The service used to authenticate users when they log in.
+The hub _uses_ these providers to authenticate but does not store authentication credentials on them. The user or their home institution has a direct relationship with the identity provider.
+
+Personal data processed by this sub-processor (exchanged at login only):
+
+- Username
+- Email address (depending on the provider)
+- Membership in a designated organization (where applicable)
+
+Here are a few common ones we use:
+
+- **GitHub**. [Privacy Statement](https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement)
+- **CILogon**. operated by the [University of Illinois NCSA](https://www.cilogon.org/about)
+- **Google**. [Privacy & Terms](https://policies.google.com/privacy)
+
+**Note**: If a hub uses CILogon, the user's home institution is itself the identity provider and effectively the relevant sub-processor for that user's authentication data.
+
+(data-processor:find)=
+## How to find the data processors for a specific hub
+
+The sub-processors used by a given hub are determined by its configuration in the [2i2c infrastructure repository](https://github.com/2i2c-org/infrastructure/).
+This will usually involve digging through `.yaml` configuration to find the services that your hub uses.
+If you need this information, please [open a support ticket](../../support.md).
+
+## Related
+
+- [](./privacy.md). what data 2i2c does and does not retain
+- [](./acceptable-use.md). expectations for using 2i2c-managed infrastructure