Banking & Practical

EU Privacy Rules (GDPR) for Foreign-Owned Companies: The Working Basics

Updated: 19 August 2026 Holdwise editorial team GDPR Privacy Compliance

For a normal commercial company, GDPR compliance means five working habits, three documents and knowing where you send personal data. Foreign owners of a Dutch company need this practical level, and they can skip the legal theory behind it. At Holdwise, we keep this answer up to date and change it when the rules change.

The five working habits

First, know your data. Keep a register of processing activities that lists which data you keep, why and for how long. Second, have a legal basis for each purpose, such as a contract, a legitimate interest or consent. Third, sign agreements with your processors. You need a processing agreement with every tool and supplier that handles personal data. Fourth, answer requests from individuals within one month, for access, correction and deletion. Make one mailbox responsible for these requests. Fifth, report breaches that pose a risk to people to the authority within 72 hours. If you report late, the risk of a fine is higher.

Extra points for foreign owners

In a group, there is an extra question about data transfers. If you send personal data to a parent company outside the EU, you need a named safeguard. This is an adequacy decision where one applies, or otherwise standard contractual clauses. Name this safeguard in the privacy notice. See data residency, the question customers ask. As controller, the Dutch BV keeps compliance at one EU address, and purchasing teams see this as a plus. For health and education, there are separate sector rules. See healthtech and EU privacy and edtech in Europe.

Each year, every Dutch BV files the same set of documents. These are the VAT returns, the corporate tax return, the annual accounts at the KVK and the UBO check. We do all of it for you. See corporate secretarial services in the Netherlands.

A Dutch BV files the corporate tax return by 1 June, the VAT return every quarter and the payroll tax return every month. The annual accounts are due within twelve months. See running a Dutch BV: taxes, filings and every deadline.

What the authorities check

Authorities and auditors check the basics. Is the register in place, and do the privacy notices match what you do? Are the agreements signed, are requests answered and are breaches reported? For a normal company, one day of setup and a yearly review are enough. You can also use this work to answer the security questionnaires of large customers. See answers to practical questions.

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Frequently asked questions

Do you need a data protection officer? +

Only if you monitor people on a large scale or process large amounts of sensitive data. Most commercial companies fall outside this duty. They can name an internal person responsible for privacy instead. Checking which category applies to you takes about ten minutes.

Is it a problem if your parent company is in the US? +

It is fine if you document the transfer. Use an adequacy decision or standard contractual clauses, name the transfer in the privacy notice and record it in agreements within the group. When this is in writing, reviewers accept it. When it is missing, a buyer finds a problem in the due diligence.

When was this last checked? +

Reviewed 19 August 2026. The rules are stable, and enforcement practice keeps improving.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 19 August 2026