Best Practices for Managing Paper Documents and GDPR Compliance

The General Data Protection Regulation (GDPR) covers more than just digital data. It also applies to paper documents containing personal data. GDPR includes paper documents and printed documents, not just digital data. Physical files and paper records must be protected with the same care as electronic data.

This guide explains how GDPR applies to paper documents, including employee files, client contracts, and other records. The European Union established the GDPR, which applies to both paper records and digital files. Organisations must manage all types of data storage to meet the requirements of the GDPR.

The challenge is to extend data protection beyond IT systems to thousands of paper documents stored across offices and filing cabinets. Every paper containing personal information about an identifiable natural person or a natural person falls under the GDPR rules.

Key Takeaways

• Key considerations for managing paper documents under GDPR include secure storage, restricted access, and proper destruction methods.

• Organisations must have comprehensive data protection policies for both digital and paper documents to guarantee compliance with GDPR requirements.

• Using certified shredding services is a GDPR compliant method for destroying confidential documents and sensitive information, helping to prevent data breaches and maintain legal obligations.

Legal Framework

GDPR is technology-neutral. It protects personal data regardless of how it is stored. GDPR safeguards the rights of the data subject, whether their information is stored electronically or on paper. Paper documents are subject to the same rules as electronic files.

In the UK, the Data Protection Act (DPA 2018) supports GDPR by covering personal data in paper records and filing systems. Public authorities and any public authority are also subject to GDPR rules for paper documents.

Organisations must have a data protection strategy that addresses both paper and electronic records to guarantee compliance and prevent data breaches.

What is a Filing System?

A filing system is any organised set of personal data accessible by specific criteria. Examples include:

• Alphabetically arranged records in filing cabinets

• Chronological employee files

• Any system allowing easy traceability of personal data

What Counts as Processing?

Processing includes (but is not limited to):

• Reading

• Storing

• Organizing

• Retrieving

•Destroying

This applies to both paper documents and digital data.

Legacy Documents

Documents created before May 25, 2018, must also comply if they are still processed for legitimate purposes.

Cross-Border Impact

GDPR applies to paper documents containing data about EU residents, regardless of the location of your organisation.

Key Concepts for Paper Documents

Personal data in paper documents includes:

• Names and addresses

• CVs with employment history

• Visitor sign-in sheets with signatures

• Client correspondence, including location data

• Handwritten notes about identifiable persons

• Documents containing personal identities, such as copies of ID cards or passports

Organisations must have policies covering both digital and paper data.

GDPR Principles for Paper Document Management

GDPR’s data protection principles apply to paper documents:

• Lawfulness, fairness, and transparency

• Purpose limitation

• Data minimisation

• Accuracy

• Storage limitation

• Integrity and confidentiality

Organisations must apply appropriate protections for paper documents to uphold these principles.

These principles impact how you manage temporary and remote workers, satellite offices, and any location storing sensitive documents.

Security and Access Control

• Use locked cabinets and secure storage rooms

• Implement clean desk policies

•Restrict access to authorised personnel only

• Regularly review security measures

Document Retention and Destruction

• Follow retention schedules based on document type, keeping confidential paperwork until the end of its retention period.

• Securely destroy documents when no longer needed. Ensure the safe destruction of confidential paperwork and documents to minimise organisational exposure and comply with data protection regulations.

• Use certified shredding to prevent data breaches. Adopting better shredding practices is essential for GDPR compliance.

Data Minimization

• Avoid unnecessary printing of personal data

• Limit paper copies to essential business needs

Individual Rights

• Have procedures to locate and retrieve paper files quickly

• Respond to data access requests within required timeframes

• Provide GDPR training on secure document handling

Building a Paper Document Compliance Program

Integrate physical document policies with digital data protection to maintain consistent standards across all platforms.

Steps to Protect Physical Data

1. Document Inventory Audit
• Catalogue all paper files by location, content, and data type
• Include remote and temporary storage locations

2. Access Control
• Maintain access logs
• Limit filing cabinet keys to authorised staff
• Set clear protocols for document access

3. Secure Destruction
• Use certified shredding services or internal cross-cut shredders
• Destroy documents so reconstruction is impossible

4. Staff Training
• Teach proper handling, printing limits, and disposal procedures
• Cover real-world scenarios employees face daily

5. Retention Schedules
• Define timelines for different document types
• Review and destroy outdated files regularly

Document Type	Retention Period	Security Level	Destruction Method
Employee Personnel Files	6 years post-employment	High – locked cabinets	Certified shredding
Client Contracts	Industry-specific	High – restricted access	Secure destruction
Visitor Logs	1-2 years	Medium – controlled access	Cross-cut shredding
Training Records	3-5 years	Medium – locked storage	Standard shredding
Temporary Documents	Immediately after use	High – clean desk policy	Immediate destruction

Long-Term Paper Document Compliance

Legacy archives require ongoing GDPR management for years.

Digitization

• Converting paper records to digital can improve access control and retention management

• Manage scanning carefully to avoid data breaches

• Decide whether to keep paper originals or securely destroy them after digitisation

Reducing Paper Use

• Limit new paper documents containing personal data

• Use approval processes for creating paper files

• Prefer digital alternatives when possible

Action Plan

• Conduct a 30-day audit of all paper storage

•Train data protection officers and compliance teams on physical data

• Partner with certified shredding and secure storage vendors

• Maintain regular audits and clear contracts with vendors

Conclusion

Effective paper document management reduces risk, enhances efficiency, and fosters trust with customers and stakeholders.

GDPR compliance for paper documents requires the same level of care as digital data, encompassing creation, storage, access, and destruction.

Organisations with solid physical document policies will be well-prepared for audits and investigations, while effectively protecting personal data.

Frequently Asked Questions (FAQs)

1. Does GDPR apply to paper documents?

Yes, GDPR applies to all personal data regardless of its format, including paper documents. Organisations must guarantee that paper records containing personal data are managed with the same level of protection as electronic data, ensuring GDPR compliance.

2. How should organisations securely destroy paper documents under GDPR?

Organisations should use certified shredding services or secure cross-cut shredders to destroy paper documents. Secure destruction ensures that confidential documents cannot be reconstructed, thereby reducing the risk of data breaches and protecting sensitive business information.

3. What are the key security measures for managing paper documents under GDPR?

Key measures include storing paper documents in locked cabinets or secure rooms, restricting access to authorised personnel only, maintaining access logs, implementing clean desk policies, and providing GDPR training to employees on proper handling and disposal of sensitive documents.