GDPR checklist for expense management tools.
Expense and spend tools hold card transactions, receipts and travel details about employees, often linked to their bank details. Compare 7 common tools and see what to check for each.
Compared at a glance
| Tool | Usual role | Data location | Agreement |
|---|---|---|---|
 Payhawk | Depends on the activity | Often Belgium and Germany, check your account | Published by the vendor |
 Spendesk | Depends on the activity | Often European Union, check your account | Published by the vendor |
 Pleo | Depends on the activity | Often Ireland (AWS eu-west-1), check your account | Published by the vendor |
 Brex | Depends on the activity | Set per account or project | Published by the vendor |
 Navan | Usually a processor | Set per account or project | Published by the vendor |
 Perk | Usually a processor | Often Ireland, Germany, Spain and Switzerland (EEA customers), check your account | Published by the vendor |
 Yokoy | Usually a processor | Often Germany, Belgium and Switzerland, check your account | Obtained through the vendor |
What to check for expense management tools
- Limit who can see individual expenses, and review access when someone leaves.
- Check that receipts are kept only as long as accounting law requires.
- Check the role of the card issuer, which often acts as an independent controller for payment checks.
- Record the region and any transfer outside the EEA.
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Questions, answered.
What should I check before using an expense management tool under the GDPR?
Limit who can see individual expenses, and review access when someone leaves. Check that receipts are kept only as long as accounting law requires. Check the role of the card issuer, which often acts as an independent controller for payment checks. Record the region and any transfer outside the EEA.
Do I need a data processing agreement with an expense management provider?
If the provider handles personal data on your behalf, yes: Article 28 of the GDPR requires a written contract. Some providers publish the text, others give it to you inside your account. Providers that decide their own purposes may act as independent controllers instead, so check the role.
Which expense management tools does Privacyboard cover?
Payhawk, Spendesk, Pleo, Brex, Navan, Perk, Yokoy. Each has a page with its agreement, usual role and data location, checked on 1 November 2026.
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Privacyboard is not affiliated with these vendors. Checked on 1 November 2026. This is guidance, not legal advice.