How it plays out on a deal
HR files, customer lists and email archives all contain personal data. If any of it concerns people in the EU, sharing it through a data room is processing under GDPR, and the room provider acts as a processor on the seller's behalf.
In practice that means a data processing agreement, clarity on where the data is stored and who can reach it, and a plan to minimize what is shared. Redacting or pseudonymizing employee data before the confirmatory stage is common and well worth the effort.
What to check in a review or demo
- 1Whether a GDPR-compliant data processing agreement is offered as standard.
- 2Where data is stored, and how transfers outside the EU are covered.
- 3Which sub-processors the provider uses and how changes are announced.
Read alongside
- Data processing agreement (DPA)The contract annex in which the room vendor promises how it will treat personal information on your behalf: safeguards, who else it may use, cross-border moves and deletion at the end.
- Data residencyWhich jurisdiction physically hosts a room's files, and whether the customer can pick it, for instance an EU, UK, US or Australian region chosen when the room is created.
- RedactionBlacking out names, figures or personal details so they are gone from the shared copy itself, not just hidden behind a box.
- ISO 27001ISO/IEC 27001 sets out how an organization should run its security program as a managed cycle of risk assessment, controls and review.