GDPR - Is having a PDF with fields to fill out classed as data?
<p>I have a website which has a link to a PDF form which users can print out and fill in. I'm wondering if somewhere I need to a statement in my privacy policy which justifies this?</p>

<p>There is no requirement about "data" in the GDPR, so provided this is just "data", no. An <em>empty</em> form with fields for personal data contains no personal data.</p>

<p>On the other hand, if the form is filled in by the user with <em>personal</em> data (as defined in GDPR article 4), <em>and</em> you receive a copy of the filled in form and <em>process</em> these personal data (as defined in GDPR article 4) - then the answer is: Yes.</p>

<p>However, if you <em>do not</em> process the personal data (i.e. the form is just printed out on paper and filled in with a pen, and nobody except the data subject has access to the piece of paper with the filled in form - then the answer again is "no").</p>

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