GDPR compliance isn’t a checkbox you tick once. It’s a set of ongoing habits around how personal data — including personal data that shows up inside ordinary business documents like invoices, contracts, and HR records — is collected, stored, shared, and eventually deleted. This checklist covers the document-handling side of that work: the practical questions worth asking about your day-to-day archive, independent of any particular software.
General information versus product behavior: the checklist items below describe what the GDPR (opens an external site) — Regulation (EU) 2016/679 — asks organizations to think about. Where Paperplane’s own features are relevant to an item, that’s called out separately and explicitly, so it’s clear which is regulatory background and which is a product capability.
1. Know what personal data is actually in your documents
Most organizations underestimate how much personal data sits inside routine files: names and addresses on invoices, bank details in contracts, health information in HR files, signatures on forms. The GDPR’s data-protection principles — including data minimization and purpose limitation — apply to this data the same way they apply to a structured database. Start by identifying which document types in your archive commonly contain personal data, rather than assuming only your CRM or HR system counts.
2. Establish a lawful basis and purpose
Under the GDPR, processing personal data requires a lawful basis (such as a contract, a legal obligation, or legitimate interest) and a defined purpose. For document archives this usually means: you keep an invoice because tax law requires it, or a signed contract because it documents an agreement — not “because it might be useful someday.” Document why each major document category is retained; it makes later retention and deletion decisions much easier.
3. Set — and follow — retention periods
The GDPR requires that personal data not be kept longer than necessary for the purpose it was collected for (storage limitation). In practice, this means defining retention periods per document type (commercial correspondence, tax-relevant records, employment files) and actually deleting or archiving-out documents once those periods expire, rather than accumulating everything indefinitely “just in case.” Retention periods themselves are often set by other laws (tax, employment, commercial law) that interact with GDPR rather than replace it — a general checklist can’t tell you the exact number of years for your jurisdiction and document type, so treat this as a prompt to look that up for your specific case.
4. Control who can access which documents
Access should be limited to people who need it for a legitimate purpose — a common-sense reading of the GDPR’s data-minimization principle applied to internal access, not just external sharing. Practical checks: Are old employees’ access rights actually revoked? Can anyone in the company open HR or payroll folders? Is client data visible to people who don’t work on that client?
Where Paperplane fits: documents shared with people outside your workspace go out through read-only sharing links you can revoke at any time, rather than open folders or email attachments. A link can be open to anyone who has it (optionally with a password), limited to specific email recipients who confirm with a one-time code, or limited to people in your workspace. Inside the workspace, roles (Member, Admin) and access groups narrow who can open a given document without you having to build that control yourself.
5. Know how you’d respond to a data-subject request
The GDPR gives individuals rights including access, rectification, and erasure of their personal data. If someone asks “what documents do you hold about me,” your organization needs a realistic way to search for and produce (or delete) documents that reference them — not just structured database records. A document archive with real full-text search makes this materially more feasible than searching folder names and hoping.
6. Secure documents without overclaiming
Appropriate technical and organizational security measures are a GDPR requirement, but the specifics (encryption standards, key management, hosting location, certifications) are implementation details that vary by provider and deployment. Ask any document-management vendor directly what they can verify about encryption, backups, and data location — don’t accept vague reassurance, and don’t assume a feature exists because it seems likely. Paperplane does not present itself as GDPR certified, and no software vendor can make an organization GDPR compliant on its own — compliance is an organizational responsibility that software can support but not substitute for.
7. Keep an eye on processors and sub-processors
If a document-management provider (or its connectors, hosting, or AI functionality) involves other companies processing data on your behalf, GDPR requires that this happen under appropriate contracts and that you have visibility into who those processors are. Ask your vendor for this information rather than assuming it doesn’t apply because the product “just stores files.”
8. Log what happens to sensitive documents
Being able to show when a document was accessed, shared, or signed — and by whom — supports both accountability (a core GDPR principle) and your own ability to investigate an incident. Signature requests and sharing links that carry a status history are useful here specifically because they create that trail without extra manual logging.
9. Plan for breach response, not just prevention
The GDPR requires notifying supervisory authorities of certain personal-data breaches within strict timeframes, and sometimes notifying affected individuals directly. A document-handling checklist should include: who gets notified internally if a shared link or an account is compromised, and how quickly you could determine which documents were exposed.
10. Review this checklist periodically
Retention needs, team structure, and tooling change. A checklist reviewed once at onboarding and never again tends to drift out of relevance. Revisit it at least yearly, or whenever you change document-management tools or connect a new integration.
Non-legal-advice notice
This checklist summarizes general GDPR concepts for document handling and is not legal advice. It does not account for your specific industry, jurisdiction, contracts, or risk profile. For an authoritative reading of your obligations, consult a qualified data-protection professional or legal counsel, and refer to the full regulation text (opens an external site) and the European Commission’s data-protection guidance (opens an external site) for the current official wording.