11 January 2025
Are Paper Test Drive Forms GDPR Compliant?
Short answer: In most cases, no—or at least, they create unnecessary compliance risk.
Paper test drive forms are still widely used by car dealerships across Europe and the UK. While they may feel simple and familiar, they pose significant challenges under GDPR and similar privacy regulations.
This article explains why paper-based test drive forms are risky, what GDPR actually requires, and what dealerships can do to reduce exposure.
Why dealerships still use paper forms
Paper test drive forms are common because they:
- Are easy to introduce
- Require no IT setup
- Have “always worked”
But GDPR changed the rules around how customer data must be handled, not just how it’s collected.
What GDPR requires for test drive data
When a dealership collects customer data for a test drive—such as:
- Name
- Contact details
- Driving licence information
- Signature or consent
…it becomes a data controller under GDPR.
That comes with obligations, including:
1. Purpose limitation
You may only collect data for a specific, legitimate purpose (e.g. administering a test drive).
2. Storage limitation
You must not keep personal data longer than necessary for that purpose.
3. Security
You must protect personal data against unauthorized access, loss, or misuse.
4. Accountability
You must be able to demonstrate compliance, not just claim it.
Where paper forms fall short
Paper forms create compliance gaps in several areas:
No enforceable retention period
Paper forms are often stored:
- In filing cabinets
- In desk drawers
- On shelves in back offices
There is rarely a systematic way to delete them after a set period (e.g. 30 or 60 days).
Difficult to restrict access
Anyone with physical access to the office may access customer data—intentionally or not.
No audit trail
If asked:
“When was this customer’s data deleted?”
Most dealerships cannot answer confidently when using paper.
High risk during audits or complaints
If a customer requests deletion or raises a complaint, paper records are slow, manual, and error-prone to manage.
Are paper forms illegal under GDPR?
Paper forms are not explicitly illegal.
However, GDPR requires that data controllers:
- Implement appropriate technical and organisational measures
- Reduce risk where reasonably possible
In practice, this means that continuing to use paper when digital alternatives exist is increasingly hard to justify, especially for routine processes like test drives.
A safer approach: digital, purpose-built systems
Digital test drive systems like DriveConsento allow dealerships to:
- Capture consent clearly
- Apply predefined retention periods
- Automatically delete data when it’s no longer needed
- Prove compliance if questioned
This dramatically reduces risk compared to paper-based processes.
Key takeaway
Paper test drive forms expose dealerships to avoidable GDPR risk.
Even if they haven’t caused problems yet, they:
- Don’t scale
- Don’t support accountability
- Don’t meet modern expectations of data protection
For dealerships serious about compliance, moving away from paper is no longer optional—it’s a matter of risk management.
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