ERP GDPR Data Protection Compliance Guide
ERP systems store and process extensive personal data including employee records, customer contact information, vendor representative details, and transaction histories that fall under GDPR protection requirements. Achieving GDPR compliance in ERP requires systematic data mapping, lawful basis documentation, consent management, data subject rights implementation, and ongoing data protection governance. This guide provides actionable steps for making your ERP system GDPR-compliant.
Personal Data Mapping and Lawful Basis Documentation
GDPR Article 30 requires organizations to maintain a Record of Processing Activities (ROPA) documenting every category of personal data processed in the ERP system. Data mapping identifies all tables and fields containing personal data, categorizes the data by sensitivity level, documents the lawful basis for processing (consent, contract, legitimate interest), and records data retention periods. For ERP systems, personal data typically exists in customer master records, vendor contacts, employee records, sales transaction histories, and communication logs.
- Map all ERP tables containing personal data: customer master (name, email, phone, address), vendor contacts, employee records
- Classify personal data fields by GDPR category: standard personal data, special category data (health, ethnicity), and financial data
- Document lawful basis for each processing activity: contract performance (orders), legitimate interest (analytics), consent (marketing)
- Create ROPA entries for each ERP module documenting data categories, purposes, recipients, transfers, and retention periods
- Identify and document all third-party data sharing from ERP (reporting services, payment processors, logistics providers)
Data Subject Rights Implementation
GDPR Articles 15-22 grant data subjects specific rights that must be operationally supported within your ERP system. The right of access (Article 15) requires the ability to extract all personal data for a specific individual across all ERP modules. The right to erasure (Article 17) requires deletion or anonymization of personal data when no longer needed, balanced against legal retention requirements (tax records, financial audit trails). Implementing these rights in ERP requires custom data extraction queries, anonymization procedures, and legal hold management.
- Build data subject access request (DSAR) procedures extracting all personal data for an individual across all ERP modules within 30 days
- Implement right-to-erasure procedures with anonymization scripts that replace personal identifiers with pseudonymous values
- Configure data retention policies per module: financial records (7-10 years legal hold), marketing data (consent withdrawal triggers deletion)
- Balance erasure requests against legal retention obligations: anonymize personal identifiers while preserving transaction records for tax compliance
- Create data portability export procedures generating structured CSV/JSON files for Article 20 data portability requests
Data Protection Impact Assessment and Governance
GDPR Article 35 requires Data Protection Impact Assessments (DPIAs) for processing activities that present high risk to data subjects. ERP implementations, major upgrades, and new module deployments processing personal data typically trigger DPIA requirements. Ongoing GDPR governance includes privacy by design in ERP customization projects, data breach notification procedures for ERP security incidents, and regular assessment of data processing activities against documented purposes and lawful bases.
- Conduct DPIA for new ERP implementations, module deployments, and integrations that process personal data at scale
- Implement privacy by design principles in ERP customization: data minimization, purpose limitation, and storage limitation
- Establish data breach notification procedures for ERP incidents: 72-hour notification to supervisory authority per GDPR Article 33
- Conduct annual GDPR compliance reviews assessing ERP data processing against documented ROPA entries and lawful basis records
- Train ERP users on GDPR awareness covering data handling obligations, breach reporting procedures, and data subject rights
Need GDPR compliance for your ERP system? Netray delivers comprehensive data mapping, DPIA assessments, and compliance implementation services.
Related Resources
ERP Security Best Practices Guide
Implement comprehensive ERP security best practices covering access control, encryption, monitoring, and compliance aligned with NIST CSF and CIS Controls frameworks.
ERPERP Audit Trail Configuration Guide
Configure comprehensive ERP audit trails covering transaction logging, change tracking, data retention policies, and audit-ready reporting for SOX and ISO compliance.
ERPERP Encryption for Data at Rest and in Transit
Configure data encryption for ERP systems covering TLS transport security, database encryption at rest, key management, and compliance with NIST and PCI DSS standards.