HR & payrollCharlieHR and the GDPR: agreement, role and data location.
CharlieHR 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
- Set per account or project
- Agreement
- Published by the vendor
What does CharlieHR do with personal data?
Manage employee records, payroll, time off and other HR processes. That is how Privacyboard describes a typical use of CharlieHR, 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 CharlieHR a processor or a controller?
Most customers use CharlieHR 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 CharlieHR store personal data?
CharlieHR does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
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.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to CharlieHR?
For the usual use of CharlieHR, 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 CharlieHR have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. CharlieHR 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, revision March 2026, signed 18 Mar 2026 by Charlie OS Limited as processor. No single hosting location stated; sub-processor annex lists Heroku and AWS in Ireland and Google Cloud as global. Transfers use the ICO's UK IDTA.
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 CharlieHR agreementHow to declare CharlieHR
- 1
In your privacy policy
Name CharlieHR 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 CharlieHR 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 CharlieHR 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 CharlieHR
- 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 CharlieHR GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how CharlieHR 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 CharlieHR have a DPA?
Yes. CharlieHR 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://static.charliehr.com/security/CharlieHR-Data-Processing-Addendum-2026-03-18.pdf.
Is CharlieHR a data processor?
Usually, yes. Most customers use CharlieHR 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 CharlieHR?
For the usual use of CharlieHR, 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 CharlieHR store data?
CharlieHR does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. 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.
Do I need to mention CharlieHR in my privacy policy?
Yes, if CharlieHR 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 CharlieHR to my vendor list?
In Privacyboard, pick CharlieHR 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 CharlieHR. 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.