AccountingXero and the GDPR: agreement, role and data location.
Xero is a accounting 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
- Accounting
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Xero do with personal data?
Keep accounts, issue invoices and manage bookkeeping. That is how Privacyboard describes a typical use of Xero, as a starting point you can edit.
The data usually involved: customer and supplier names, contact details, invoices, payment records and bank transaction details.
Is Xero a processor or a controller?
Most customers use Xero as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for accounting 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 Xero store personal data?
Xero 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 Xero’s data processing terms and your organisation’s region in its settings.
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.
Does Xero have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Xero publishes the text of its data processing agreement 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: Full text on the Irish edition of the site. Last updated Feb 2025. Other regions have their own page. No hosting location is stated.
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 Xero agreementHow to declare Xero
- 1
In your privacy policy
Name Xero as a recipient, say what it is used for (keep accounts, issue invoices and manage bookkeeping) 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 Xero 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 Xero 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 Xero
- Limit access to people who need the books, and review it when someone leaves.
- Agree how long invoices are kept: accounting law often sets a minimum.
- Check the region and any transfer outside the EEA.
- Record whether your accountant also has access, as a separate recipient.
Questions, answered.
Is Xero GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Xero 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 Xero have a DPA?
Yes. Xero publishes the text of its data processing agreement 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.xero.com/ie/legal/terms/data-processing/.
Is Xero a data processor?
Usually, yes. Most customers use Xero as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does Xero store data?
Xero 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 Xero’s data processing terms and your organisation’s region in its settings.
Do I need to mention Xero in my privacy policy?
Yes, if Xero 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 Xero to my vendor list?
In Privacyboard, pick Xero 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.
Privacyboard is not affiliated with Xero. 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.