gdpria.eu

How do I complete a customer's privacy questionnaire?

The questionnaire asks about what you already record in your processing register

A privacy questionnaire from a customer usually covers the same topics as the processing register: which personal data are processed, for what purpose, how long they are retained, who has access to them, and whether a processor is involved. Anyone who already has that register in order can answer most questions directly from it. Questions about security — encryption, access controls, backups — fall under the technical and organisational measures that the customer wants to see before sharing data with you.

Part of the questionnaire often concerns the organisation around it: is a data protection officer appointed, is there a procedure for a data breach, and who is it reported to. The latter varies by country: in the Netherlands it is the Dutch Data Protection Authority, in Germany the supervisory authority of the state where the establishment is located. The obligation to appoint a data protection officer yourself has no threshold based on staff numbers in the Netherlands — this follows from Article 37 GDPR — whereas Germany uses a number of employees as a limit under § 38 BDSG. For a reader active in multiple countries, it is therefore important to check per establishment which level applies, rather than giving one answer for the entire organisation.

Justification: the accountability obligation of Article 5 GDPR

That a customer asks this kind of questions and that you can answer them follows from the accountability obligation of Article 5 GDPR: an organisation must not only comply with the principles of the regulation, but also be able to demonstrate this. A questionnaire is essentially the customer placing part of his own accountability obligation on you. The Dutch Data Protection Authority publishes general guidance on these principles, without this resulting in a format for a customer questionnaire — each customer fills this in themselves.

What this is based on

The regulation itself is on EUR-Lex. We refer per statement; you do not need to believe us.

What you need to do in practice

The implementation for each obligation, including the deadlines involved and the templates to document it, is included in the subscription.

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This is not legal advice. This page provides general information about the regulation that this platform is about. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-20. Is something incorrect? Let us know — corrections take priority.