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Quality · buyer guide

GDPR requirements in a software specification: what to write down before anyone builds

Why GDPR belongs in the specification rather than a policy written after launch, five examples of requirements to write down, and what the European Commission says the law expects.

Published 13 October 2026 · Pricient by IOanyT

The short answer

GDPR expects data protection to be built in from the earliest design stage, so it belongs in the specification, not in a policy written after launch. Write down which personal data the app collects and why, how long it keeps it, who can see it, how people get or delete their data, and what happens in a breach. Fines reach €20 million or 4% of turnover.

What the law expects, in the Commission’s words

RequirementWhat the European Commission says
Data protection by designMeasures “at the earliest stages of the design of the processing operations”, such as pseudonymisation and encryption
Data protection by defaultThe most privacy-friendly setting from the start — only the data needed, kept for the shortest time, accessible on a need-to-know basis
Requests from individualsAnswered without undue delay, in principle within 1 month, free of charge
BreachesReported to the supervisory authority within 72 hours of becoming aware, if likely to risk people’s rights
FinesUp to €20 million or 4% of total annual worldwide turnover

Sources: European Commission — Obligations, Dealing with requests from individuals, Enforcement and sanctions. Checked 5 October 2026.

Five examples of GDPR requirements worth writing down

Examples, not a complete list, with illustrative wording — the right set depends on what your app does and whose data it holds.

  1. What is collected, and why. “At sign-up we collect name and email to create the account. We do not collect date of birth.” A field nobody can justify is a field to remove.
  2. How long it is kept. “Closed accounts are deleted after 30 days; invoices are kept for the period tax law requires.” Without this, everything is kept forever by default.
  3. Who can see it. “Support staff see a customer’s orders, not their payment details.” By default means need-to-know.
  4. How people exercise their rights. “A user can download their data and request deletion from their account page; requests are logged and answered within one month.”
  5. How a breach is noticed. “Unusual access to customer records raises an alert to a named person.” You cannot report within 72 hours what you never noticed.

Each one is testable. That is the point of putting them in the specification: when the app is delivered, you can check it does what the requirement says.

Why after launch is too late

A privacy policy written after launch describes what the app happens to do. A specification written before build decides what it should do. Retention rules, access limits and data export are cheap as requirements and expensive as retrofits — they reach into screens, data structures and every report already built.

What to ask a vendor about GDPR

  1. Where in the specification are the GDPR requirements? If the answer is “in the privacy policy”, they are not in the build.
  2. Which outside services will hold personal data — and where?
  3. How will a user get or delete their data?
  4. What evidence will you receive to show the app does what the requirements say?
  5. Does the vendor claim to make you compliant? Nobody’s vendor can.

How Pricient handles GDPR

You do not have to know which framework applies — the project tells us, and the quote carries it. When a project involves personal data of EU residents, GDPR is spotted, not left to you, and its requirements are written into the specification you receive before you pay anything. The evidence an auditor asks for — a control-mapping binder, data-flow diagrams showing where personal data enters, moves, rests and leaves, and drift checks that fail the build if a later change breaks a control — is produced as the work is done.

Audit-ready by default, never self-certified. We do not make you compliant; we make your auditor’s job faster. This guide is general information, not legal advice.

More on quality and compliance →

Questions

Asked about this

Why does GDPR belong in a software specification?

Because the law expects it at design time. The European Commission says organisations should implement technical and organisational measures "at the earliest stages of the design of the processing operations" — data protection by design. Requirements added after launch mean reopening work already paid for.

What GDPR requirements should a specification include?

At minimum, examples like these: what personal data is collected and why; how long each kind is kept; who can see it; how a person gets a copy of their data or has it erased; and how a breach is noticed and reported. This is not a complete list — the right set depends on what the app does.

How quickly must a business respond to a GDPR request or breach?

According to the European Commission, requests from individuals must be answered without undue delay and in principle within one month, free of charge. A breach likely to put people's rights at risk must be reported to the supervisory authority within 72 hours of becoming aware of it.

Can a development firm make us GDPR compliant?

No. Compliance is an obligation of the organisation that decides how personal data is used. A good build makes it far easier: the requirements are in the specification, the app does what they say, and the evidence is there when you need it. This guide is not legal advice.

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