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I have a website which has a link to a PDF form which users can print out and fill in. I'm wondering if somewhere I need to a statement in my privacy policy which justifies this?

  • Does your website ever see the data that the users enter into the form? – phoog May 10 '18 at 15:11
  • @phoog, it does not matter - unless the form self-destructs as soon as the user says it is complete, it is probably stored somewhere (OPs website or third party). Both are "processing" as defined by the GDPR. – Free Radical May 10 '18 at 15:29
  • @FreeRadical well, no, under normal circumstances the data entered into a PDF form are only saved if the user saves the file, therefore usually on the user's computer or in a location of which the website owner is unaware and over which the website owner has no control. In such a situation, the website owner is not processing the user's data. Furthermore, the order in the question ("print out and fill in") suggests that there's no user data on the form at all, but I assume that the question has it backward. – phoog May 10 '18 at 15:35
  • @phoog, mea culpa. I overlooked the "print out and fill in". I assumed this was an electronic PDF. I shall amend the answer, taking this into account. – Free Radical May 10 '18 at 15:41
  • Hey folks, thanks for your help. Yes the form will be printable and can't be filled out electronically. – Shaun May 10 '18 at 16:06
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There is no requirement about "data" in the GDPR, so provided this is just "data", no. An empty form with fields for personal data contains no personal data.

On the other hand, if the form is filled in by the user with personal data (as defined in GDPR article 4), and you receive a copy of the filled in form and process these personal data (as defined in GDPR article 4) - then the answer is: Yes.

However, if you do not process the personal data (i.e. the form is just printed out on paper and filled in with a pen, and nobody except the data subject has access to the piece of paper with the filled in form - then the answer again is "no").

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