GDPR in a Law-Firm CRM: Data Processing Agreements, Server Location, Deletion Periods
What GDPR requires of a law-firm CRM: an Art. 28 data processing agreement, EU hosting, deletion periods and data subject rights – explained concisely.
GDPR requires a law-firm CRM to rest on a valid legal basis for every processing activity, a data processing agreement under Art. 28 GDPR with the provider, data processing on European servers, and clearly defined deletion periods alongside enforceable data subject rights. For lawyers, professional confidentiality is added on top – here, data protection is not a comfort feature but an obligation.
Legal basis: why every processing activity must be justified
Every processing of personal data needs a legal basis under Art. 6 GDPR. In a law firm this is usually the initiation and performance of the mandate (contract), plus legitimate interests when maintaining a professional network. A CRM that captures contacts automatically must be able to reflect these bases – for example by distinguishing client, prospect and pure network contacts, and by letting the firm control granularly who sees which information.
The data processing agreement (DPA, Art. 28 GDPR)
As soon as an external provider processes personal data on the firm's behalf, a data processing agreement is mandatory. It governs the subject and duration of processing, the type of data, the provider's obligations, technical and organizational measures, and the firm's audit rights. Without a DPA, the processing is formally unlawful – no matter how secure the software is technically.
For law firms it is equally decisive that the provider is contractually bound to confidentiality. Only then can professional secrecy be safeguarded toward the service provider as well. More on this in BRAO-compliant CRM.
Server location and EU hosting
Where the data is stored is a core criterion. Processing within the EU avoids the legal uncertainties of third-country transfers. Ideally, the CRM runs on the same infrastructure the firm already uses.
Doraly takes exactly this approach: data is processed on European Microsoft Azure servers – the same infrastructure that also runs Office 365. Client data is also never used to train AI models.
Deletion periods and data minimization
GDPR requires that data be kept only as long as the purpose demands (storage limitation) and that only what is necessary is processed from the start (data minimization). In practice this means defined deletion concepts: when are contacts deleted that no longer relate to a mandate? Which professional and commercial retention periods take precedence? A good CRM makes these decisions visible and controllable rather than accumulating data indefinitely.
Subprocessors
If the provider itself uses service providers – for hosting or email synchronization, for instance – those are subprocessors. The firm must know who is involved, and the DPA must govern their inclusion. Transparency over the chain of processors is a precondition for the firm to meet its own accountability obligation. The section Security & Compliance shows how Doraly bundles these topics.
Data subject rights
Clients and contacts have rights to access (Art. 15), rectification (Art. 16) and erasure (Art. 17). A CRM must support these rights technically: records must be findable, exportable and fully deletable. Features such as tags, lists and a clean network analysis help not only with mandate work but also with responding to a data subject request in a structured way. The post CRM for law firms describes which features are useful here.
Conclusion
A GDPR-compliant law-firm CRM stands on four pillars: a clear legal basis, a robust data processing agreement, an EU server location, and a well-thought-out deletion and access concept. Doraly was developed in collaboration with IT lawyers, processes data on European Microsoft Azure servers, contractually binds the provider to confidentiality, and never uses client data for AI training – so that data protection and professional duties fit together from the start.