GDPR for indie SaaS — the minimum viable compliance playbook
You're a one-person SaaS with a handful of EU customers. Do you need to be GDPR compliant? Yes. Here's the minimum viable version — what to collect, what to publish, what to skip until you're bigger.
GDPR applies to any service offered to residents of the EU, no matter how tiny the provider. It is not the overwhelming monster the internet makes it out to be — a solo SaaS founder can reach defensible compliance in a long weekend. This guide covers the minimum viable path.
What it is
The EU General Data Protection Regulation (Regulation 2016/679) governs how personal data about EU residents is collected, stored, and transferred. Enforcement is by national Data Protection Authorities (DPAs). Fines scale to 4% of global revenue or €20M, whichever is higher — but in practice, first-time small-business violations are handled with warnings and required remediation, not instant fines.
Vulnerable example
# Common mistakes that put indie SaaS in violation
- Using Google Analytics without IP anonymization or consent
- Storing EU user data on US servers without Standard Contractual Clauses (SCCs)
- Collecting emails for "newsletter" without opt-in checkbox and unsubscribe link
- No published Privacy Policy, or a copy-pasted one that describes the wrong data
- Keeping user accounts forever after deletion request
- Logging IP addresses in Sentry/LogRocket without a legal-basis clauseFixed example
# Minimum viable GDPR checklist
1. Publish a Privacy Policy (8-12 sections, template-driven)
2. Ask for explicit consent before any non-essential tracking
3. Offer a one-click deletion workflow (not just "email us")
4. Add a cookie banner if any tracking cookie is set
5. Sign DPAs with every sub-processor you use (Stripe, Vercel, Supabase, etc.)
6. Use Standard Contractual Clauses for EU→US transfers
7. Respond to data-subject requests within 30 days
8. Notify affected users within 72 hours of a qualifying breachHow Securie catches it
Securie's privacy specialist is on the Series-A roadmap; today the tool library includes the Privacy Policy template at /templates/privacy-policy and the DPA template at /templates/dpa.
Checklist
- Privacy Policy published at /legal/privacy (plain-English, 10-15 minute read)
- Cookie banner that blocks non-essential tracking until accepted
- Published list of sub-processors (/sub-processors or inside Privacy Policy)
- DPA signed with every SaaS vendor you send personal data to
- Standard Contractual Clauses in place for any EU→US data transfer
- Data-subject-access-request workflow documented and tested
- User-deletion workflow documented and tested (30-day deadline)
- Breach-notification plan (72-hour regulator + affected-user notifications)
- Legal basis declared for every type of personal data you collect
- Data-retention schedule published (how long each data type is kept)
FAQ
Do I really need GDPR compliance for 10 EU customers?
Yes. GDPR applies to any non-EU service offered to EU residents. The penalty risk scales with size — enforcement actions against solo founders are rare and usually warning-based — but compliance is genuinely not optional. The good news: the minimum viable version takes one long weekend and costs ~$0 if you use template policies.
Do I need a DPO (Data Protection Officer)?
Only if you (a) are a public authority, (b) process sensitive data as a core activity, or (c) monitor data subjects at scale. A typical B2B SaaS under 100 employees does not need a formal DPO. You can appoint yourself as the privacy contact and publish that email.
What about Schrems II and US data transfers?
If any of your infrastructure (Vercel, Supabase, Stripe, Sentry, etc.) processes EU personal data in the US, you need Standard Contractual Clauses (SCCs) or a Transfer Impact Assessment. Every major US SaaS publishes SCCs; signing them is a click in most cases. Document which vendor has which clauses.
Do I need to notify regulators about a breach?
GDPR Article 33 requires notification to the supervisory authority within 72 hours of becoming aware of a personal-data breach that poses risk to rights and freedoms. If the risk is low (e.g. encrypted data at rest compromised but encryption keys not), notification may not be required — document the assessment regardless.
Can I just copy another company's Privacy Policy?
Legally no, practically yes — but customize the data categories, sub-processors, and retention periods to match your product. A copy-pasted policy that describes the wrong data collection is worse than no policy. See /templates/privacy-policy for a customizable starting point.