GDPR Compliance Checklist for SaaS Companies

Why GDPR matters for SaaS companies

If your SaaS product collects, stores, or processes personal data from individuals in the European Union, GDPR applies to you — regardless of where your company is headquartered. Fines can reach 4 percent of global annual revenue or 20 million euros, whichever is greater. Beyond fines, GDPR violations damage trust, complicate enterprise sales, and create legal liability.

The good news: GDPR compliance isn’t as overwhelming as it looks, especially for SaaS companies that already follow reasonable data practices. Most of the work is about documentation, process, and being intentional about how you handle personal data.

The checklist

Lawful basis and transparency

• Identify your lawful basis for each type of data processing (consent, contract, legitimate interest, legal obligation, vital interests, or public task).
• Update your privacy policy to clearly explain what data you collect, why, how long you retain it, and who you share it with. Write it in plain language.
• Implement cookie consent that allows users to accept or reject non-essential cookies before they’re set. Pre-checked boxes don’t count.
• Document consent records — if you rely on consent, keep records of when and how consent was given.

Data subject rights

GDPR gives individuals specific rights over their personal data. Your product and processes must support them:

• Right of access — users can request a copy of their personal data. Build an export mechanism.
• Right to rectification — users can correct inaccurate data. Ensure your product allows profile editing.
• Right to erasure — users can request deletion of their data. Implement a deletion workflow that covers your database, backups, and third-party integrations.
• Right to data portability — users can request their data in a machine-readable format (JSON, CSV).
• Right to object — users can object to processing based on legitimate interest. Have a process to handle objections.
• Response timeline — respond to all data subject requests within 30 days.

Data protection by design

• Minimize data collection — only collect personal data you actually need. Review your signup forms, analytics, and logging.
• Implement encryption at rest and in transit for all personal data.
• Pseudonymize or anonymize data where possible, especially in development and staging environments.
• Set retention periods — define how long you keep each category of personal data, and automate deletion when the period expires.
• Conduct a Data Protection Impact Assessment (DPIA) for high-risk processing activities (profiling, large-scale processing of sensitive data, systematic monitoring).

Organizational measures

• Appoint a Data Protection Officer (DPO) if required (public authority, large-scale monitoring, or large-scale processing of sensitive data). Even if not required, designate someone responsible for data protection.
• Maintain a Record of Processing Activities (ROPA) documenting every processing activity, its purpose, legal basis, data categories, recipients, and retention period.
• Train your team — all employees who handle personal data should understand GDPR basics and your company’s data protection policies.
• Establish a data breach notification process — you must notify the supervisory authority within 72 hours of discovering a breach that poses a risk to individuals.

Third-party and vendor management

• Sign Data Processing Agreements (DPAs) with every third-party processor that handles personal data on your behalf (cloud providers, analytics tools, email services, support platforms).
• Assess sub-processor compliance — ensure your vendors maintain adequate data protection standards.
• Document international data transfers — if personal data leaves the EEA, ensure you have a valid transfer mechanism (Standard Contractual Clauses, adequacy decision, or binding corporate rules).
• Maintain a sub-processor list and notify customers of changes, as required by your DPA.

Technical security measures

• Access control — implement role-based access with least-privilege principles. Use MFA for all internal systems.
• Logging and monitoring — maintain audit logs of access to personal data. Monitor for unauthorized access.
• Regular security testing — conduct vulnerability scans and penetration tests on a regular cadence.
• Secure development practices — code reviews, dependency scanning, and security testing in your CI/CD pipeline.

Common gaps for SaaS companies

1. No data deletion workflow — many SaaS products can create accounts but have no way to fully delete them, including from backups and third-party integrations.
2. Cookie consent theater — implementing a consent banner that doesn’t actually block cookies until consent is given.
3. Missing DPAs — using dozens of SaaS tools without data processing agreements in place.
4. Over-collection — collecting data “just in case” instead of with a specific purpose.
5. No breach response plan — the 72-hour notification window is tight. Without a pre-defined process, most teams can’t meet it.

GDPR and other frameworks

GDPR compliance overlaps significantly with ISO 27001 — particularly around access control, encryption, incident response, and risk management. If you’re pursuing ISO 27001, you’re already covering many GDPR technical requirements. Similarly, SOC 2 Privacy criteria align with GDPR’s data protection principles.

For a detailed comparison, see our guide on ISO 27001 vs SOC 2.

Get started

AuditFront’s GDPR self-assessment templates walk you through every requirement with practical guidance. Run a gap analysis to see exactly where you stand and what needs attention.

Start your free GDPR assessment and turn this checklist into an action plan.