Navigating data portability challenges for SaaS providers under GDPR

In the digital age, data is one of the most valuable assets. For Software as a Service (SaaS) providers, the responsibility of handling and processing vast amounts of user data brings both opportunity and significant regulatory obligation. The General Data Protection Regulation (GDPR) introduced by the European Union has added layers of complexity to how this data is managed, shared and protected. Among its provisions, the right to data portability enshrined in Article 20 stands out as a key aspect of user empowerment. For SaaS providers, it presents a unique set of challenges, but also a clear path to building trust and competitive differentiation when handled correctly.

This article dives deep into the legal foundations of data portability, translates regulatory requirements into actionable strategies, highlights common challenges for SaaS providers, and provides practical tools and solutions.

Understanding data portability under GDPR

Article 20 of the GDPR grants individuals the right to receive personal data they have provided to a controller in a structured, commonly used, and machine readable format. It also gives them the right to transmit that data to another controller without hindrance, where the processing is based on consent or contract and carried out by automated means.

The intent is to empower users to switch services with minimal friction, supporting competition and user autonomy.

Data portability therefore includes:

• Data actively provided by the user, such as account details or user profiles.
• Observed data, like search history or usage logs (as long as it reflects user activity).

It does not include inferred or derived data, such as algorithmic scores or analytics, which were generated by the controller.

Translating regulation into practice

To meet GDPR’s data portability requirements in a meaningful, efficient, and user-friendly way, SaaS providers should follow a structured approach:

Conduct a data inventory

Start with a complete mapping of the personal data you process. Identify:

• Where the data is stored
• What systems interact with it
• Whether it’s user-provided, observed, or inferred

This helps determine what data is subject to portability.

Use standardised, machine-readable formats

Standardising formats reduces complexity when transmitting data between platforms. Ensure that exportable data can be provided in formats like:

• CSV (great for spreadsheets and structured lists)
• JSON (ideal for APIs and structured metadata)
• XML (still common in legacy systems)

Implement secure data transfer mechanisms

Data portability does not mean compromising data security. Security must be upheld throughout the process to avoid breaches. Secure transfer options include, at minima:

• TLS/HTTPS for web-based exports
• OAuth2 or secure APIs for controller-to-controller transfers
• Encryption at rest and in transit.

Build authentication and verification processes

GDPR requires that requests be fulfilled without “undue delay,” but not at the expense of security. To prevent unauthorised access:

• Authenticate users before fulfilling data portability requests.
• Use multi-factor authentication if data sensitivity is high.

Automate the request process

Manual handling of portability requests can be error-prone. Automation tools can help manage:

• Request intake
• Identity verification
• Export formatting
• Timely delivery

It also supports auditability and compliance tracking.

Embedding portability into product design (Privacy by Design)

One of the most effective ways to address GDPR data portability is to build it directly into your product architecture using Privacy by Design (PbD) principles. Article 25 of the GDPR mandates that data protection measures be embedded “by design and by default.” For SaaS platforms, this means developing systems that facilitate the export, transmission, and structured storage of user data from the ground up.

When launching new features or services, consider:

• Structuring databases to separate user-submitted data from derived insights to avoid accidental inclusion of non-portable elements.
• Tagging fields that are considered user-provided or observable to enable selective export.
• Creating a ‘portable snapshot’ service within your platform, allowing users to preview or retrieve their data without contacting support.

This proactive approach is not just about compliance but also reduces operational friction and enhances the overall user experience. Users are increasingly privacy conscious and providing them with a seamless self-service data export option reinforces transparency and trust.

Moreover, integrating portability mechanisms early can avoid costly architectural retrofits later. APIs designed with portability in mind (e.g. using RESTful principles, including standardised pagination and authentication) enable both manual and automated data transfers while maintaining consistency and security.

Preparing for interoperability in a multi-platform ecosystem

A growing challenge in data portability is interoperability, i.e the ability to move data not just between companies, but across entirely different platforms and ecosystems. As SaaS tools increasingly integrate with others (e.g. CRMs, HR platforms, payment processors), users expect their data to remain functional and intact post-transfer.

GDPR does not mandate interoperability, but it’s widely seen as the natural evolution of data portability.

For SaaS providers, anticipating this trend means:

• Supporting standardised schemas for common data types (e.g using schema.org, ActivityPub, or FHIR in healthcare).
• Collaborating with industry consortiums working on cross-platform standards.
• Designing APIs and export formats that allow re-importing, reducing vendor lock-in and building goodwill.

While full interoperability remains a work in progress across industries, early adoption of open standards and transparent export schemas can position SaaS providers as leaders in privacy-first design.

Quick action plan for SaaS providers GCs

1. Review current compliance: audit your systems and policies to understand where gaps exist.
2. Update your privacy policies: clearly explain to users what data is portable and how to request it.
3. Develop internal procedures: create SOPs for data portability, from request intake to delivery.
4. Test the system: run internal simulations to test timing, accuracy, and security of your process.
5. Train your staff: customer service, support, and legal teams should understand how to handle requests.
6. Log and document everything: maintain a record of requests, decisions, and exports to demonstrate accountability.

While data portability is a regulatory requirement, it can also be a competitive differentiator. Offering clear, easy-to-use export tools increases user trust and makes your platform “stickier”, paradoxically making users less likely to leave.

Framing portability as a feature strengthens your brand. It signals maturity, transparency and customer respect.