RawboardWhat a report really contains
Check the columns of your export. Sales and staff reports often include:
- customer names (sometimes phone, address, email);
- employee names and their data (sales per employee, hours worked, schedule);
- order information which, in an optical practice, can reveal health data (prescriptions, lens types, implied diagnoses).
If the report contains such data, it is, under the GDPR, a collection of personal data, and health data belongs to the special categories, with stricter rules.
What changes when you upload it online
An online tool that receives your file is usually your processor: it processes the data on behalf of your company. In that case the GDPR requires a contract or legal act between you and the provider (Article 28) and that processing happens only on your instructions. If the servers are outside the European Economic Area, the transfer rules (Article 44 onwards) apply too.
In short: it is not forbidden, but it means one more provider to check, to mention in your notices to employees and customers and to bind with an agreement. The minimisation principle (Article 5) also requires you to send only what the purpose needs.
A checklist before uploading a report
| Question | Why it matters |
|---|---|
| Where are the servers (EU or outside the EU)? | transfers outside the EEA have their own rules |
| Is there a data processing agreement (DPA)? | the GDPR requires one between controller and processor |
| How long do they keep the file, and can I delete it? | unlimited retention contradicts minimisation |
| Do they use my data to train models or for other purposes? | any other purpose needs its own legal basis |
| Who at the provider has access to the file? | access should be limited |
| Can I anonymise the report first (no names, no phone numbers)? | the simplest risk-reduction measure |
The alternative: it stays with you
An app that runs locally, on your computer, with no internet connection, avoids the problem at its root: there is no third party to receive the data. Rawboard is built that way. It is a single file that opens in the browser; the page is not allowed to open any internet connection (its security policy allows no external connections or scripts), and the first screen shows “External resources loaded right now: 0”. The archive of reports stays in that computer’s browser and your original files are never modified. The licence is checked locally with a digital signature, with no server.
That does not mean the app frees you from GDPR duties for the data in your reports: you remain responsible for your customers’ and employees’ data. It only means it does not add one more provider to the chain.
A few common-sense rules, whatever the tool
- Export only the columns you need; remove phone numbers and addresses if they do not matter for the report.
- Do not email exports to just anyone; use a secure channel.
- Delete old exports from the Downloads folder.
- If you use an online service, read its data terms before the first upload.
More on getting the numbers out of an export without sending the data anywhere in How to build a sales report from Excel.
Frequently asked questions
Is it illegal to upload an export with customer data to an online tool?
What is a data processing agreement?
Does Rawboard send my data anywhere?
If I use an offline app, do I still have GDPR duties?
Sources and further reading
Optometrist with over ten years in medical optics. Writes about what works in a real practice or shop, and builds the apps that daily work called for.
About the author
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