GDPR for SaaS & Software in Ireland
A practical country and industry compliance guide — obligations, evidence, and next steps.
Direct answer
SaaS & Software organisations in Ireland must document a lawful basis for every processing activity, maintain an Article 30 ROPA, implement 72-hour breach notification, and complete DPIAs for high-risk processing. Enforcement is led by DPC (Data Protection Commission), which is one of Europe's most active GDPR supervisors.
What are the GDPR obligations for SaaS & Software in Ireland?
SaaS & Software organisations in Ireland must document a lawful basis for every processing activity, maintain an Article 30 ROPA, implement 72-hour breach notification, and complete DPIAs for high-risk processing. Enforcement is led by DPC (Data Protection Commission), which is one of Europe's most active GDPR supervisors.
- Audit all customer contracts for Article 28 DPA clauses
- Publish a sub-processor list and customer notification process
- Complete transfer impact assessment for US infrastructure providers
- Document security baseline in ROPA and processor security annex
| Country | Ireland |
| Industry | SaaS & Software |
| Regulation | Regulation (EU) 2016/679 |
| Supervision | The DPC is the lead supervisory authority for most major US tech companies with EU headquarters in Ireland (Meta, Google, Apple, LinkedIn, TikTok), making it the most scrutinised DPA in Europe |
The GDPR applies to any organisation that processes personal data of EU/EEA residents, regardless of company size or location. Obligations include lawful basis for processing, data subject rights, a 72-hour breach notification, Article 30 records of processing, DPIA for high-risk processing, DPO appointment where required, and data-transfer safeguards for non-EU services.
GDPR enforcement is fully active across all 27 member states. DPA fines exceeded €4 billion cumulative through 2025. Enforcement is intensifying in healthcare, HR and AdTech.
Source: Regulation (EU) 2016/679, Articles 5, 6, 13, 14, 17, 25, 30, 32, 33, 35 and 37
SaaS & Software GDPR checklist
Action checklistDocument which Article 6 lawful basis (consent, contract, legitimate interest, legal obligation, vital interest, public task) applies to each processing activity, and record it in your Article 30 ROPA.
Articles 6, 30
Your ROPA must list: controller identity, purposes, data categories, data subjects, recipients, retention periods, international transfers, and security measures. Update it whenever processing changes.
Article 30
Prepare a documented incident response procedure so that a personal data breach is reported to your national DPA within 72 hours of discovery. Assess risk to data subjects and notify them if risk is high.
Articles 33, 34
A DPIA is mandatory before processing that is likely to result in high risk to individuals — large-scale profiling, systematic monitoring, sensitive data, biometrics, automated decision-making.
Article 35
A DPO is mandatory for public authorities, organisations that process special categories of data at scale, and those that systematically monitor individuals at scale. Voluntary DPOs are best practice.
Articles 37–39
Apply encryption, pseudonymisation, access controls, regular backups and security testing. Document your security measures in the ROPA and review after incidents or significant system changes.
Articles 25, 32
What is specific to Ireland
The DPC is the lead supervisory authority for most major US tech companies with EU headquarters in Ireland (Meta, Google, Apple, LinkedIn, TikTok), making it the most scrutinised DPA in Europe. For Irish-established organisations, the DPC expects detailed ROPA, Schrems II-aligned transfer impact assessments for US services, and DPO registration. The DPC has issued the largest GDPR fines to date.
Priority actions for SaaS & Software
- Audit all customer contracts for Article 28 DPA clauses
- Publish a sub-processor list and customer notification process
- Complete transfer impact assessment for US infrastructure providers
- Document security baseline in ROPA and processor security annex
Turn this guide into a real assessment
Use EuroComply's free tools to check your specific scope, estimate fine exposure, and build an evidence file.
Informational only. This page is not legal advice — consult qualified counsel for your specific situation. Last reviewed: .