HR & payroll15Five and the GDPR: agreement, role and data location.
15Five is a hr & payroll tool. Most customers use it as a processor, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- HR & payroll
- Usual role
- Usually a processor
- Data location
- Often United States, check your account
- Agreement
- Published by the vendor
What does 15Five do with personal data?
Manage employee records, payroll, time off and other HR processes. That is how Privacyboard describes a typical use of 15Five, as a starting point you can edit.
The data usually involved: employee names, contact details, contract and payroll data, bank details, absences and other HR records.
Is 15Five a processor or a controller?
Most customers use 15Five as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for hr & payroll tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does 15Five store personal data?
15Five is usually associated with United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account.
What 15Five says (read on 2026-11-05): “15Five's primary processing operations take place in the United States” Source: https://www.15five.com/hubfs/DPA%202026_Publish.pdf
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Which legal basis usually applies to 15Five?
For the usual use of 15Five, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Employment contracts, payroll and the records employers must keep (tax, social security, working time) rest on the contract and on employment law.
Health data such as sick notes is sensitive: limit who can see it and rely on an employment-law condition of Article 9.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does 15Five have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. 15Five publishes the text of its data processing agreement as a PDF on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
What we noted when we opened the page: Data Processing Addendum (Exhibit E to the MSA), 13 Oct 2026 version. Contracting entity 15Five, Inc. States primary processing operations take place in the US; EU SCCs (Modules One and Two), UK Addendum and Swiss terms; DPF not mentioned.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the 15Five agreementHow to declare 15Five
- 1
In your privacy policy
Name 15Five as a recipient, say what it is used for (manage employee records, payroll, time off and other HR processes) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add 15Five with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link 15Five to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on 15Five
- Limit access to HR and managers who need it, and review it when someone leaves.
- Set retention periods per record type: payroll and contracts often have legal minimums, candidates and former staff do not keep forever.
- Check where the data is hosted and any transfer outside the EEA.
- Tell employees which tool holds their data in your staff privacy notice.
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Questions, answered.
Is 15Five GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how 15Five is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does 15Five have a DPA?
Yes. 15Five publishes the text of its data processing agreement as a PDF on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://www.15five.com/hubfs/DPA%202026_Publish.pdf.
Is 15Five a data processor?
Usually, yes. Most customers use 15Five as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use 15Five?
For the usual use of 15Five, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Employment contracts, payroll and the records employers must keep (tax, social security, working time) rest on the contract and on employment law. Health data such as sick notes is sensitive: limit who can see it and rely on an employment-law condition of Article 9.
Where does 15Five store data?
15Five is usually associated with United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account. What 15Five says (read on 2026-11-05): “15Five's primary processing operations take place in the United States” Source: https://www.15five.com/hubfs/DPA%202026_Publish.pdf
Do I need to mention 15Five in my privacy policy?
Yes, if 15Five handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add 15Five to my vendor list?
In Privacyboard, pick 15Five from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with 15Five. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.