GDPR Compliance for Invoice Processing: Complete Checklist
Processing invoices with EU customer data? This guide covers every GDPR requirement: data protection, encryption, storage, retention, and audit procedures.
GDPR Fines Are Serious
Non-compliance can cost up to €20 million or 4% of annual revenue, whichever is higher.
Use this checklist to ensure your invoice processing is fully compliant.
What Personal Data Is in Invoices?
Under GDPR, invoices often contain personal data that must be protected:
- • Customer names (individuals or sole proprietors)
- • Addresses (billing and shipping)
- • Email addresses and phone numbers
- • VAT numbers (linked to individuals)
- • Bank account details (for payment)
- • Purchase history (line items reveal behavior)
If you process invoices from EU residents, you're a data controller and must comply with GDPR.
GDPR Compliance Checklist
1. Legal Basis for Processing
You must have a lawful basis to process invoice data. For B2B invoices, this is typically:
- • Contract performance: Processing invoices is necessary to fulfill the contract
- • Legal obligation: Tax laws require invoice retention (6-10 years depending on country)
2. Data Minimization
Only collect and store data necessary for invoicing:
- ✓ Required: Invoice #, vendor, date, total, line items
- ✗ Avoid: Social security numbers, credit card full numbers, unnecessary contact info
TIPBest Practice:
If extracting invoice data with OCR, configure your system to exclude fields not required for accounting (e.g., customer IDs, notes).
3. Encryption & Security
Protect invoice data with appropriate technical measures:
At Rest
- • AES-256 encryption for stored PDFs
- • Encrypted database fields
- • Access controls (role-based)
In Transit
- • TLS 1.3 for all connections
- • Secure email (S/MIME or PGP)
- • SFTP for file transfers
✓ Quixyl Security:
Quixyl uses AES-256 encryption, TLS 1.3, and infrastructure following SOC 2 principles. All invoice data is encrypted at rest and in transit.
4. Data Retention & Deletion
Invoices must be retained for tax purposes but deleted when no longer needed:
- • Minimum: 6-10 years (check local tax laws)
- • Maximum: Delete after legal retention expires
- • Right to erasure: May not apply during legal retention period
⚠️ Important:
Implement automated deletion policies. Manual deletion is error-prone and creates compliance risk.
5. Data Processing Agreements (DPAs)
If using a third-party invoice processor (like Quixyl), you must have a DPA that specifies:
- • Processing purpose and duration
- • Data security measures
- • Sub-processor disclosure
- • Data breach notification procedures
- • Audit rights
6. Data Subject Rights
You must be able to respond to these requests within 30 days:
- • Access: Provide copies of all invoices containing their data
- • Rectification: Correct errors in invoice data
- • Portability: Export invoice data in machine-readable format (CSV, JSON)
- • Erasure: Delete after legal retention period expires
7. Breach Notification
If invoice data is exposed, you must:
- • Notify supervisory authority within 72 hours
- • Notify affected individuals if high risk to rights
- • Document the breach in your records
- • Implement measures to prevent recurrence
8. Audit & Documentation
Maintain records to prove compliance:
- • Data processing activities register
- • DPAs with all processors/sub-processors
- • Security policies and procedures
- • Employee training records
- • Data breach incident log
Country-Specific Requirements
Invoice Retention Periods (EU)
- • Germany: 10 years
- • France: 6 years
- • UK: 6 years
- • Spain: 6 years
- • Italy: 10 years
- • Netherlands: 7 years
- • Poland: 5 years
- • Sweden: 7 years
⚠️ Note: Always retain for the longest applicable period if processing invoices across multiple countries.
Process Invoices Securely with Quixyl
Quixyl is designed for GDPR requirements with security practices aligned with SOC 2 principles, AES-256 encryption, and standard DPAs.
- ✓ EU data centers available
- ✓ Automated retention policies
- ✓ Data subject request portal
- ✓ Audit logs & compliance reports