If you're developing a mobile app for European users or collecting any data from EU residents, the General Data Protection Regulation (GDPR) is something you need to understand and follow closely.
Whether your app collects user information for analytics, login purposes or personalizes the user experience, GDPR compliance is essential.
In this guide, we’ll break down what GDPR is, why it matters, and how you can ensure your mobile app stays compliant.
What is GDPR?
The General Data Protection Regulation (GDPR) is a privacy law implemented in 2018 that sets strict guidelines on how personal data of EU residents is collected, stored, and processed. It applies to any company or app—regardless of its location—that handles the personal information of people living in the European Union. GDPR is all about giving users control over their personal data and ensuring that organizations treat this data with care and transparency.
Why it’s important
GDPR is important because it protects user rights. As developers, our users trust us with their personal information—things like email addresses, names, location data, and more. GDPR aims to make sure this data is handled responsibly and securely. For developers and businesses, complying with GDPR isn’t just about avoiding penalties (though that’s important); it’s also about building trust with your users, which can lead to better engagement and loyalty over time.
Penalties for non-compliance
The penalties for failing to comply with GDPR can be severe. If your app is found to violate GDPR rules, fines can be as high as €20 million or 4% of your company’s global annual revenue —whichever is greater. Beyond the financial costs, non-compliance can harm your app's reputation, leading to a loss of user trust. This is why it's essential to take GDPR compliance seriously from the start of development.
Understanding data controller, processor, and subject
Before diving into how to make your app GDPR-compliant, it’s important to understand three key roles defined under the regulation:
Data controller: This is the entity (person, company, or app) that determines the purpose and methods of processing personal data. If you own the app and decide what data is collected and why, you are the data controller.
Data processor: This is the entity responsible for processing data on behalf of the controller. For example, if you use a third-party service that stores user data, like a BaaS platform, that service acts as a processor.
Data subject: This is the individual whose personal data is being collected. In the context of your app, it’s your user.
Both the data controller and processor have to follow GDPR, but the controller carries more responsibility for making sure everything is compliant. That said, processors aren’t off the hook—if there’s a data breach or they don’t follow the rules, they can be held directly accountable too. That’s why it’s important to make sure any third-party tools that interact with your user data are also GDPR-compliant.
How to turn your mobile app GDPR-compliant
1. Conduct a data audit
The first step in making your app GDPR-compliant is to understand the data it collects and processes. Conduct a full audit of the data flow within your app. Ask yourself these questions:
What personal data are you collecting (names, emails, location, etc.)?
How are you collecting this data (through forms, cookies, etc.)?
Why are you collecting this data, and is it necessary?
Where and how is the data being stored?
This audit helps identify unnecessary data collection and ensures that you're only handling data you truly need, a principle known as data minimization, which is a key component of GDPR.
2. Build the feature to obtain explicit user consent
One of the central principles of GDPR for mobile apps is explicit user consent. You cannot collect or process personal data unless the user has clearly agreed to it. For mobile apps, this typically means:
Pre-consent notices: Before any data is collected, you need to ask for permission, explaining what data will be collected, why, and how it will be used.
Opt-in mechanisms: Use clear and transparent opt-in forms rather than pre-checked boxes or ambiguous language. In many cases, the mobile OS will take care of this with a pre-developed box.
Withdrawal of consent: Users must have a simple way to withdraw consent at any time, such as disabling tracking in app settings.
For example, if your app uses cookies or other tracking technologies to monitor user activity, you must get consent before activating those trackers, even in a mobile environment.
3. Provide access to user data
GDPR gives users rights over their personal data, including the right to access and the right to be forgotten. Your app needs to make it easy for users to:
View the data you've collected about them.
Request corrections if the data is inaccurate.
Delete their data upon request (right to be forgotten).
You can implement a user-friendly dashboard within your app where users can manage their data or offer a simple contact method where they can request data access or deletion.
4. Implement privacy by design
Privacy by design means integrating data protection into your app’s development from the start. It’s not something you can add on later; it should be built into every part of your app.
Key privacy-by-design practices include:
Data minimization: Collect only the data you need and avoid storing unnecessary information.
Anonymization: When possible, anonymize or pseudonymize user data to reduce risk in case of a data breach.
Secure default settings: Ensure that the most privacy-protective settings are enabled by default for users.
By adopting these principles, you create an app that prioritizes user privacy and security at its core.
5. Update your privacy policy
GDPR requires that you have a transparent and detailed privacy policy that explains how personal data is collected, processed, and stored. This policy should include:
What personal data is collected.
Why the data is collected.
How the data is processed and stored.
How users can access or delete their data.
Who the data is shared with (if any third parties are involved).
Your privacy policy should be easy to find and written in clear, simple language, avoiding legal jargon. Make sure users can access this information easily before they give consent.
6. Ensure secure data storage and transfer
Data security is a critical component of GDPR. You need to protect user data from unauthorized access, breaches, or leaks. To achieve this:
Encrypt personal data both in transit and at rest to prevent unauthorized access.
Use secure servers and ensure that any third-party services or cloud providers you use are GDPR-compliant.
Regularly update your security protocols to stay ahead of potential vulnerabilities.
Implementing these practices not only helps with GDPR compliance but also adds a layer of trust for your users.
7. Ensure third-party services are GDPR-compliant — or find alternatives
Under GDPR, it’s your responsibility to make sure any third-party data processors are also GDPR-compliant. Third-party data processors can include cloud storage providers, analytics platforms, or payment processors — essentially, any external service that handles your users' data.
For example, if you’re using a backend platform like Firebase that handles your databases or authentication, you need to keep in mind that it’s not fully GDPR-compliant out of the box. Firebase’s data handling, particularly with data transfers outside of the EU, can make meeting GDPR requirements tricky and put extra burden on you to ensure compliance.
Appwrite provides a GDPR-compliant alternative to Firebase. Appwrite is an open-source backend-as-a-service platform that gives you full control over where your data is stored and processed. With Appwrite, you can ensure that all user data stays within the EU, making GDPR compliance much simpler.
Final thoughts
Turning your mobile app GDPR-compliant involves more than a few technical tweaks—it requires a thoughtful approach to how you collect, use, and protect user data. By adhering to GDPR's principles of transparency, security, and user control, you can not only avoid hefty fines but also build trust with your users, creating a more secure and responsible app experience.
Learn more about how to build a GDPR-compliant app and Appwrite’s approach to security and compliance:
