The short answer: When an employee leaves your company, you must ensure that personal data is not left behind, taken with them, or forgotten. This requires clear oversight of data ownership, access rights, and documented procedures. Under GDPR, you are obligated to protect personal data – even at offboarding.
Employee turnover is the new normal
In recent years, frequent job changes have become more common. This places new demands on businesses – not just in terms of recruitment and onboarding, but also in data security. So what actually happens to sensitive personal data when an employee leaves? In this blog, we explore how employee turnover can impact your data – and what you need to consider to stay GDPR-compliant and strengthen compliance.
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Employee turnover and data management
Employee exits are often associated with direct costs: recruitment, onboarding and lost productivity. But the hidden cost of lost data, unauthorised access and GDPR violations can be far more damaging. Departing employees may – knowingly or unknowingly – take sensitive data with them. It might be stored in personal email accounts, local folders, USB drives or unregulated cloud services, or simply remain accessible due to poor offboarding routines.
Once data leaves your organisation’s control, you no longer have a legal basis for processing – but you still hold responsibility. Under GDPR, it is the data controller who is accountable for any accidental sharing, loss or misuse of personal information.
Where the real risk lies when staff leave
A lack of structured offboarding can lead to major security vulnerabilities. Many businesses doesn’t value awareness and thus underestimate how much sensitive data can be scattered across devices, accounts, and silos. In particular, three recurring risk areas should be on your radar:
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Dark data and data silos: Information stored outside managed systems – such as on desktops, USBs or Google Drive – with no classification or oversight.
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Lack of deletion or handover: Sensitive data can remain in former employees’ emails, folders or private note-taking tools.
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Orphaned access rights: Former employees who still have access to CRMs, customer files or cloud platforms pose an active risk.
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A GDPR Risk Assessment gives you a complete overview of files containing privacy risk in your company.
What does GDPR say about handling staff data?
GDPR requires clear safeguards for personal data, including during employee departures. Article 24 and 32 obligate you to implement appropriate technical and organisational measures – including revoking access rights as soon as processing purposes expire, such as when an employee leaves.
Further, Article 5(2) establishes the principle of accountability: you must be able to demonstrate responsible data handling throughout the entire lifecycle – including deletion, transfer, or archiving when staff leave.
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How to handle data when employees leave
1. Map access before it’s too late
Identify which systems and types of data the employee has had access to – including email accounts, local folders, cloud platforms, CRMs, and document-sharing tools.
Use a data discovery tool such as DataMapper to scan for sensitive files and classify risk.
2. Build a structured offboarding routine
Make data review and cleanup a standard part of your offboarding process:
- Review and assess the employee’s personal data holdings
- Transfer or delete relevant files
- Log all changes made
- Revoke system access rights immediately
- Investigate personal cloud accounts if needed
3. Involve the right people
Ensure collaboration between HR, IT, team leads and your DPO. Data protection relies on cross-functional coordination, especially when it comes to shared ownership and risk.
4. Prioritise high-risk files
Pay special attention to payroll data, customer information, legal documents, contracts and sensitive communications. These should be moved to secure locations, deleted or reassigned appropriately.
A practical checklist
Before someone leaves your organisation, don’t just hand over responsibilities – manage the data they’ve handled. Use this checklist:
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Identify data ownership and access
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Review and clean up sensitive data
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Ensure deletion or handover
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Document the process
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Use automated scanning to uncover overlooked files
FAQ on GDPR and employee turnover
1. What is our responsibility as data controllers?
You must demonstrate that data is processed only as long as necessary, and that access is revoked upon exit (Art. 5(2) and Art. 32).
2. Can former employees retain access to data?
No. Any access must be removed immediately to avoid unauthorised processing.
3. What is “dark data”?
Data stored outside of monitored systems – such as in personal notebooks, email drafts, or desktop folders – with no oversight or retention policy.
4. Do we need to document our offboarding process?
Yes. GDPR requires you to document that you have conducted a systematic review and ensured secure handover or deletion.
Turnover is inevitable – but risk is not
You can’t stop staff from leaving, but you can reduce the risks that come with it. With a data discovery tool, you can quickly identify which data a departing employee has accessed, where it’s stored, and what actions are needed. At Safe Online, we’ve developed DataMapper to make that process both secure and efficient.
Learn more
Sebastian Allerelli
Founder & COO at Safe Online
Sebastian is the co-founder and COO of Safe Online, where he focuses on automating processes and developing innovative solutions within data protection and compliance. With a background from Copenhagen Business Academy and experience within identity and access management, he has a keen understanding of GDPR and data security. As a writer on Safe Online's Knowledge Hub, Sebastian shares his expertise through practical advice and in-depth analysis that help companies navigate the complex GDPR landscape. His posts combine technical insight with business understanding and provide concrete solutions for effective compliance.
