If you share files that contain information about EU residents—client details, employee records, customer support logs—you’re operating under the GDPR. The good news: you don’t need to be a lawyer to get this right. You need a clear process, sensible safeguards, and a toolset that makes secure sharing the default.

Who needs to comply (and when)

You’re covered if you share files that include personal data of people in the EU/EEA—whether your company is based in the EU or not.
“Personal data” includes anything that can identify a person directly or indirectly: names, emails, IP addresses, photos, IDs, HR docs, contracts, support tickets.
Your role matters: the organization deciding “why and how” data is processed is the controller; vendors handling data on your behalf are processors. File sharing often involves both.

The principles that shape your file‑sharing process

Lawfulness and transparency: have a lawful basis (e.g., contract, consent, legitimate interests) and be clear with people about what you’re doing.
Data minimization: only share what’s needed. Strip attachments, remove embedded metadata, and avoid sending entire folders when a single file will do.
Storage limitation: keep access time‑bound. If a link doesn’t need to live forever, it shouldn’t.
Integrity and confidentiality: protect data in transit and at rest; restrict who can download; verify recipients.
Accountability: document decisions, keep simple records of what you shared, with whom, and when access was revoked.

Practical controls to apply when sharing files

Use expiring links instead of permanent cloud folders.
Add a passcode and share it via a separate channel (e.g., SMS if the link goes through email).
Limit downloads to the minimum necessary.
Prefer HTTPS end‑to‑end; avoid public Wi‑Fi for sensitive transfers.
Remove unnecessary personal data and metadata before sending (thumbnails, EXIF, comments, hidden sheets).
Keep a lightweight log of shares for accountability and audits.
Revoke access as soon as the task is done; don’t rely on “we’ll remember later.”

With Comfyfile, you can set passwords, expiries, and download limits by default, and keep shares short‑lived—ideal for storage limitation and confidentiality.

Step‑by‑step: a GDPR‑friendly sharing workflow

Classify the file

Does it contain personal data? If yes, is any of it special category (health, biometrics, etc.)? Minimize or redact where possible.

Choose your lawful basis

Contract or legitimate interests are common for client deliverables; consent is appropriate for optional submissions. Note your basis in your internal tracker.

Prepare the file

Remove embedded metadata, hidden sheets, comments, drafts. Name files clearly and avoid personal data in filenames.

Share securely

Upload with a passcode, set a short expiry (e.g., 24 hours), limit downloads, and verify the recipient address.

Split channels

Send the link via email and the passcode via a different channel (chat/SMS) to reduce risk.

Record and revoke

Log the share (what, who, when, expiry). Revoke or let it auto‑expire once the recipient confirms receipt.

Handling data subject requests (DSRs)

Access: be able to locate what you shared and when. Your lightweight log should make this easy.
Rectification: if a file was wrong, resend the corrected one and revoke the old share.
Erasure: ensure time‑bound links and cleanup processes remove files after expiry.

International transfers and vendors

If your recipient or file‑sharing infrastructure is outside the EEA, ensure appropriate safeguards (e.g., Standard Contractual Clauses) and vendor due diligence.
Keep a short vendor record: where data is stored, what security features are used, and how long files persist.

Common mistakes to avoid

Permanent cloud folders shared “just in case.”
Passwords sent in the same email as the link.
No expiry or unlimited downloads for sensitive files.
Sharing entire archives instead of the exact file needed.
Forgetting to remove metadata or hidden tabs.

A quick checklist you can copy

Do we actually need to share this file? Can we minimize it?
Have we chosen and recorded a lawful basis?
Is the link expiring within a reasonable window (e.g., 24 hours)?
Is a passcode required and shared via a separate channel?
Are downloads limited and recipients verified?
Will the share auto‑expire and be cleaned up?

Adopting these habits turns GDPR from a burden into a simple routine. The combination of time‑limited links, passwords, and download caps gives you strong privacy by design—without slowing anyone down.

GDPR Compliance for File Sharing: What You Need to Know