August 9, 2025
2 min read
The applicability of the General Data Protection Regulation (GDPR) to non-profit organizations has been confirmed through regulatory interpretation and legal frameworks. GDPR governs the processing of personal data by any entity acting as a data controller or processor within the European Union (EU) and European Economic Area (EEA), regardless of profit status. Thus, non-profits processing personal data of individuals residing in the EU/EEA fall under GDPR’s scope (Regulation (EU) 2016/679).
Key points identified include:
Scope of GDPR: Non-profits are included as data controllers or processors because GDPR’s language does not exclude entities based on their organizational purpose. The regulation applies universally to personal data processing activities in the EU/EEA.
Data subjects involved: Non-profits handle personal data of employees, donors, volunteers, beneficiaries, and grantees. This includes sensitive information requiring stringent protection measures.
Obligations for non-profits: They must implement appropriate technical and organizational measures to ensure compliance, including:
Exemptions specific to non-profits: Certain exemptions exist, particularly concerning the processing of data related to ‘at risk’ minors’ well-being. These are outlined in:
These exemptions provide some relief but do not exempt non-profits entirely from GDPR compliance. Instead, they offer tailored provisions recognizing the sector’s unique challenges and sensitivities.
The findings align with established regulatory guidance emphasizing that non-profit status does not confer immunity from GDPR obligations (European Data Protection Board, 2020). Effective compliance requires dedicated resources and awareness within non-profit organizations to mitigate legal risks and protect individual rights.
