FormsQualtrics and the GDPR: agreement, role and data location.
Qualtrics is a forms tool. Most customers use it as a processor, it explains how to get 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
- Forms
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Qualtrics do with personal data?
Collect and manage responses to online forms and surveys. That is how Privacyboard describes a typical use of Qualtrics, as a starting point you can edit.
The data usually involved: respondent names, email addresses, submitted answers and any attachments collected by the form.
Is Qualtrics a processor or a controller?
Most customers use Qualtrics as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for forms 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 Qualtrics store personal data?
Qualtrics 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 Qualtrics?
For the usual use of Qualtrics, companies most often rely on legitimate interests (GDPR Article 6(1)). Replying to a message sent to the company is expected by the person who sent it.
The interest you would state: “Answering the people who contact us.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Surveys and optional questions may need consent, and a form that creates an account or an order rests on the contract. The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does Qualtrics have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Qualtrics does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Qualtrics GDPR page: customers can e-sign a GDPR-specific data processing contract via a password-protected link; otherwise the Terms of Service and MSA apply. No hosting location, entity or transfer tool stated on the page.
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.
Open the Qualtrics reference pageHow to declare Qualtrics
- 1
In your privacy policy
Name Qualtrics as a recipient, say what it is used for (collect and manage responses to online forms and surveys) 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 Qualtrics 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 Qualtrics 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 Qualtrics
- Show a short notice at the point of collection, with a link to your policy.
- Collect only the fields you need.
- Set a retention period for responses and attachments.
- Record the region and where responses are exported to.
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Questions, answered.
Is Qualtrics GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Qualtrics is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Qualtrics have a DPA?
Qualtrics does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://qualtrics.com/gdpr.
Is Qualtrics a data processor?
Usually, yes. Most customers use Qualtrics 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 Qualtrics?
For the usual use of Qualtrics, companies most often rely on legitimate interests (GDPR Article 6(1)). Replying to a message sent to the company is expected by the person who sent it. The interest you would state: “Answering the people who contact us.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Qualtrics store data?
Qualtrics 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 Qualtrics in my privacy policy?
Yes, if Qualtrics 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 Qualtrics to my vendor list?
In Privacyboard, pick Qualtrics 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 Qualtrics. 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.