This article was updated in December 2025 to reflect the latest information and best practices.
TL;DR
HR teams handle personal data at every stage of the employee lifecycle, making it crucial to understand GDPR roles and responsibilities, from data controllers and processors to DPOs and data protection authorities. Knowing who is accountable helps prevent compliance gaps, manage breaches, and protect personal data effectively. GDPR-compliant HR software further supports secure storage, controlled access, deletion routines, consent management, and the documentation needed for confident, lawful HR data security.
Table of Contents
- Why HR Data Security Matters
- Key GDPR Roles and Responsibilities Explained
- How GDPR-Compliant HR Software Supports Data Security
- FAQ About HR Data Security
- Next Steps: Build an HR process that is GDPR-compliant and data secure
Working with personal data is a daily given for every HR professional. Every application, contract, and onboarding flow requires the handling of information protected under the GDPR. But when terms like data controller, processor, and DPO enter the conversation, even experienced teams can feel like they’re navigating compliance in the dark.
The reality is that these roles shape the backbone of HR data security. When you understand who does what, it becomes much easier to run compliant, transparent, and secure HR processes. In this guide, we unpack each role and explain how they fit together in everyday HR processes.
Why HR Data Security Matters
As an HR professional, you work with personal data every day, long before someone signs a contract and long after they’ve joined the team. That makes you a central player in ensuring GDPR compliance. When personal data is mishandled, the fallout can be serious: security breaches, fines, and damaged trust across the organization.
Understanding the GDPR roles involved in HR processing helps ensure that data is handled legally, fairly, and transparently. It also gives HR teams clarity about who is responsible for what, making it easier to prevent compliance gaps before they become real issues.
Key GDPR Roles and Responsibilities Explained
The GDPR defines several roles that shape how personal data should be handled. While the terminology can seem quite complex, the responsibilities themselves are straightforward once you see how they are connected. Here’s a clear breakdown of each role and what it means for HR teams in practice.
1. Data Controller
What is a Data Controller?
A data controller is the person, company, or authority that decides why personal data is processed and how that processing should take place. In HR, this is typically the employer or organization determining how information about candidates, onboardees, and employees will be used.
Because the controller sets the purpose and conditions for processing, they hold the primary responsibility for ensuring that all handling of personal data is compliant with the GDPR. This makes the controller accountable both to data subjects and to the data protection authorities overseeing the organization’s practices.
What are the Responsibilities of a Data Controller?
The data controller is responsible for ensuring that personal data is processed legally, transparently, and in line with GDPR requirements. This includes setting the conditions for processing, overseeing any third parties involved, and reporting data breaches that may pose a risk to data subjects.
What this means in practice:
- Defining how long personal data will be stored (deletion routines)
- Deciding on the legal basis for processing
- Providing information to data subjects, such as privacy policies
- Putting a Data Processing Agreement (DPA) in place when using a processor
- Ensuring processors follow the controller’s instructions
- Reporting data breaches to the data protection authority within 72 hours
- Recognizing common breach scenarios such as lost devices, theft, misdirected emails, or security vulnerabilities.
| 💭 A SCENARIO TO PUT THINGS IN PERSPECTIVE |
| Imagine your HR team is hiring for a new role and collects candidate information through your recruitment system. Because your organization decides what data to collect, how long to store it, and who may access it, you are acting as the data controller on its behalf. If a CV is sent to the wrong recipient, or if a device containing candidate information is lost, the responsibility for assessing and reporting the breach rests with you, not the software provider processing the data. |
2. Data Subject
What is a Data Subject?
A data subject is any identifiable living person whose personal data is being processed. In an HR context, this includes anyone who provides their personal information to the organization, such as candidates, onboardees, or employees.
Whenever a person shares their data with a company, they become the data subject in that specific relationship. As data subjects, they hold key rights under the GDPR, including the right to understand how their data is used and the ability to request changes or deletion.
What are the Responsibilities & Rights of a Data Subject?
While the GDPR focuses on protecting individuals rather than assigning them formal duties, data subjects hold specific rights that guide how they interact with organisations processing their data.
What this means in practice:
- Having the right to receive information about what data is being processed and why
- Being allowed to object to certain types of data processing
- Requesting the deletion of personal data
3. Data Processor
What is a Data Processor?
A data processor is a third party that processes personal data on behalf of the data controller. Unlike the controller, the processor does not decide the purpose of the processing and must follow the controller’s instructions.
In practical terms, this can include service providers that support HR operations, such as external companies that store, transfer, or manage data according to the controller’s requirements.
What are the Responsibilities of a Data Processor?
A data processor handles personal data on behalf of the controller and must carry out the processing according to the controller’s requirements and the agreed Data Processing Agreement (DPA).
What this means in practice:
- Processing personal data only as instructed
- Meeting all obligations defined in the DPA
- Informing the controller about any sub-processors involved in the processing
- Assisting the controller with investigating and reporting data breaches
- Taking responsibility for breaches caused by not following instructions or failing to meet agreed obligations
| 💭 A SCENARIO TO PUT THINGS IN PERSPECTIVE |
| Picture this: Your company uses an external HR system to manage candidate applications. The system provider processes the personal data stored in the platform, but only according to the instructions your organization has set, such as how long data should be kept or when it should be deleted. If the provider sends information to the wrong recipient or keeps data longer than agreed, they may be responsible for the breach because they failed to follow the controller’s instructions. |
4. Sub-Processor
What is a Sub-Processor?
A sub-processor is a supplier engaged by the data processor to carry out parts of the processing on behalf of the data controller. Like the processor, the sub-processor does not decide the purpose of the processing and performs its tasks under the same limitations and obligations.
In simple terms: think of a transportation company bringing in a driver from another firm to complete a delivery. In this setup, the driver acts as a sub-processor who follows the processor’s instructions, while the processor continues to follow the instructions set by the selling company, or data controller.
What are the Responsibilities of a Sub-Processor?
A sub-processor supports the data processor with specific tasks and must handle personal data within the limits set by the processor and, ultimately, the controller.
What this means in practice:
- Processing personal data solely under the processor’s instructions
- Following the same restrictions and obligations that apply to the processor
- Not determining the purpose or scope of the processing
- Carrying out processing activities solely on behalf of the controller via the processor
5. Data Protection Officer (DPO)
What is a DPO?
A Data Protection Officer is a role within a company responsible for ensuring that personal data is processed in compliance with the GDPR and national data protection regulations. Some organizations are required to appoint a DPO, such as public authorities or those whose core activities involve large-scale processing of sensitive data, while others may choose to appoint one voluntarily.
The DPO acts as an internal expert on data protection matters, helping the company understand its obligations and maintain transparency toward data subjects.
What are the Responsibilities of a DPO?
A DPO advises the organization on GDPR compliance, ensures data subjects are informed about how their data is processed, and handles internal complaints or data breaches.
What this means in practice:
- Providing guidance on GDPR requirements
- Ensuring data subjects receive clear information about data processing
- Supporting the organization in handling data breaches
- Serving as a point of contact for questions or concerns related to data protection
| 💭 A SCENARIO TO PUT THINGS IN PERSPECTIVE |
| A data breach is suspected at your company after an email containing personal data was sent to the wrong person. The DPO steps in to guide the organization on the correct GDPR response, ensures affected individuals are informed when required, and helps manage the internal process for handling the breach. They act as the point of contact for questions about the incident and help the organisation stay aligned with its GDPR obligations throughout the investigation. |
6. Data Protection Authorities
What are Data Protection Authorities?
Data Protection Authorities are governmental bodies in each EU/EEA country responsible for ensuring that organizations comply with the GDPR. They provide guidance, interpret the regulation, and act as the official point of oversight for data protection practices.
These authorities support data controllers, data processors, and data subjects by offering information and advice on lawful data processing.
What are The Responsibilities of Data Protection Authorities?
Data Protection Authorities monitor compliance, investigate data breaches, and take necessary measures when businesses fail to meet GDPR requirements.
What this means in practice:
- Offering guidance and information on GDPR compliance
- Investigating reported data breaches
- Ordering organizations to stop processing personal data when necessary
- Imposing fines or penalties on organisations that violate GDPR rules
How GDPR-Compliant HR Software Supports Data Security
The right HR software can make GDPR compliance more manageable by supporting secure data handling throughout the employee lifecycle. Talentech’s solutions provide built-in features that help organizations meet their responsibilities as data controllers and maintain consistent data protection practices across all HR processes.
Key capabilities that support compliance:
- Secure data storage within the EU/EEA, hosted by a subcontractor certified to ISO 9001, 14001, and 27001 standards.
- Customizable deletion policies that allow HR teams to set GDPR-aligned retention rules across all Talentech systems.
- Built-in consent management to ensure the correct legal basis for processing candidate and employee data.
- Independent IT audits conducted by external providers to verify system security and protection against unauthorised access or hacking.
- Comprehensive Data Processing Agreements that define requirements for disclosure, deletion, hosting, and breach notifications.
- Granular user management so employees only receive the system access needed for their role, whether temporary or ongoing.
FAQ About HR Data Security
Who is the data controller in HR processes?
The organization or person that decides how personal data about candidates, onboardees, and employees will be used is the data controller.
What is the difference between a data processor and a sub-processor?
A data processor processes personal data on behalf of the controller. A sub-processor supports the processor and follows the same instructions, without deciding the purpose of the processing.
Who is responsible for reporting a data breach?
The data controller must report breaches that pose a risk to data subjects within 72 hours. The processor assists the controller in investigating and reporting breaches.
What is a data breach in HR?
Examples of an HR-related data breach include losing a device containing personal data, sending information to the wrong recipient, theft of company information, or a hacker exploiting a security vulnerability.
Does every organization need a Data Protection Officer?
Only some organizations are required to appoint a DPO, such as public authorities or companies that process sensitive data on a large scale. Others may choose to appoint one voluntarily. Having a DPO can be beneficial because they provide dedicated expertise on GDPR compliance and help the organisation manage data protection issues with clarity and consistency.
Next Steps: Build an HR Process that is GDPR-compliant and Data Secure
Personal data plays a central role in every HR process, which makes understanding GDPR roles essential for handling that data responsibly. By knowing who the controller, processor, sub-processor, and DPO are – and what each of these roles is responsible for – HR teams can build processes that are transparent, secure, and fully aligned with GDPR requirements.
The right tools can make this work easier. GDPR-compliant HR software supports secure data storage, clear deletion routines, controlled access, and the documentation needed to meet compliance obligations with confidence.
Want to strengthen your GDPR practices and secure your HR processes?
Book a demo with Talentech’s experts and see how our platform helps you manage personal data safely across the entire employee lifecycle.
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