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GDPR for IoT — Compliance Guide for Connected Product Companies

GDPR compliance guide for IoT manufacturers and connected product companies. Smart devices, telemetry data, product lifecycle, and EU Representative.

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The Internet of Things (IoT) creates one of the most complex GDPR compliance scenarios. Smart devices collect, transmit, and often retain personal data throughout the product lifecycle. For non-EU manufacturers of IoT products sold in the EU, Article 27 requires an EU Representative — and the risks of non-compliance are amplified by the continuous nature of IoT data processing.

IoT Data Types Under GDPR

  • Device identifiers: Serial numbers, MAC addresses, device IDs — if linked to an identifiable individual, they are personal data
  • Telemetry/usage data: Operating status, feature usage, error logs, performance data — behavioral personal data
  • Location data: GPS coordinates from connected vehicles, wearables, tracking devices — personal data with special protections
  • Environmental data: Temperature, motion, humidity readings from smart home sensors — if linked to a home, may constitute personal data
  • Audio/video data: Smart speakers, smart displays, doorbell cameras — voice recordings and video footage are clearly personal data
  • Biometric data: Smart watches measuring heart rate, sleep patterns, step counts — health data under Article 9

Product Lifecycle Data Processing

IoT products process data across multiple lifecycle phases: manufacturing (firmware, test data), installation (setup, network config), daily use (telemetry, features), firmware updates (patch management, update verification), support (diagnostics, troubleshooting), end-of-life (device decommissioning, data deletion). Each phase requires ROPA documentation. Template →

The Data Act + GDPR Intersection

The EU Data Act (effective 2024-2025) adds requirements for IoT product data sharing and portability. For non-EU manufacturers: your product data that constitutes personal data must comply with both GDPR (data subject rights) and the Data Act (data sharing obligations).

Smart Home vs Industrial IoT

Smart home (B2C): Full GDPR obligations — consumer devices processing EU resident data. EU Representative required.

Industrial IoT (B2B): Still processes personal data (machine operators, maintenance staff, facility managers). EU Representative required for contact data. Guide →

Compliance Steps

  1. Appoint EU Shield as EU Representative
  2. Map data flows across product lifecycle
  3. Conduct DPIA for high-risk features (location, biometrics)
  4. Implement privacy-by-design in firmware (minimal telemetry, local processing where possible)
  5. Update Privacy Policy with product-specific processing details
  6. Create end-of-life data deletion protocol for returned/decommissioned devices

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