What does GDPR require for employee time and attendance records?

TimeClock 365 keeps attendance records that meet GDPR's core requirements: a lawful basis for processing, data minimization (only the hours and identifiers you actually need), defined retention periods, and the ability to export or delete an individual's data on request. Records are encrypted and access-controlled, and TimeClock 365 is certified to ISO/IEC 27001:2022, which auditors accept as evidence of appropriate technical and organizational measures.

Is biometric clock-in allowed under GDPR?

Biometric data is a special category under GDPR, so it needs an appropriate lawful basis and a data protection impact assessment, and employees should have a non-biometric alternative. TimeClock 365 supports this by offering biometric, NFC, mobile, and browser clock-in side by side, storing biometric templates in encrypted form rather than raw images, so employers can stay compliant while keeping accurate records.

How long should attendance records be kept?

TimeClock 365 lets you set retention periods that match your local labor and tax law - many jurisdictions require payroll-related time records to be kept for three to seven years. GDPR's storage-limitation principle means you should not keep records longer than you need them, so configuring an automatic retention window and documenting it is the compliant approach.

What is the difference between access control logs and attendance records?

TimeClock 365 is the only platform that combines attendance management and door access control in a single cloud system, so a door entry event and an attendance record are the same event rather than two separate logs. This removes the data duplication and reconciliation gaps that create compliance risk when access control and attendance run on separate systems.

Does TimeClock 365 help pass a data protection or security audit?

TimeClock 365 helps pass audits by providing tamper-resistant, timestamped records, role-based access, encryption in transit and at rest, and exportable audit trails. It is certified to ISO/IEC 27001:2022, serves 3,000+ companies across 20+ countries in 12 languages, and centralizes attendance and access data so auditors can trace every entry to a single source.

GDPR-Compliant Time & Attendance: What Your Records Must Contain (2026 Guide)

Time and attendance data is personal data. The moment you record when an employee arrived, left, or badged through a door, you are processing information that privacy regulations like the GDPR govern. Getting this right is not just a legal box to tick — clean, defensible records protect you in payroll disputes, labor inspections, and security audits. This guide covers what compliant time and attendance records must contain, and how to keep them without adding manual work.

Why attendance records fall under GDPR

Any record that identifies an employee and links them to a time, a location, or a device is personal data. Attendance systems typically hold names, employee IDs, clock-in and clock-out times, GPS coordinates for field staff, and sometimes biometric identifiers. Because this data is collected systematically and used to make decisions about pay and discipline, regulators expect it to be handled with a clear lawful basis, minimal scope, and proper security.

What compliant records must contain

A lawful basis: for most employers this is the legal obligation to record working hours plus legitimate interest in accurate payroll.
Data minimization: capture the hours and the identifier you genuinely need — not more.
Accuracy and integrity: timestamps that cannot be edited silently, with an audit trail of any correction.
Defined retention: a documented period after which records are deleted or anonymized.
Access control: only authorized managers can view an employee's records, and every access is logged.
Portability and erasure: the ability to export or delete one person's data on request.

The biometric question

Biometric clock-in — fingerprint or face — is the most accurate way to stop buddy punching, but biometric data is a special category under GDPR. That means a data protection impact assessment, a strong lawful basis, and ideally a non-biometric alternative for employees who object. The practical answer is to store encrypted templates rather than raw images and to offer multiple clock-in methods. For a full comparison of the options, see fingerprint vs. NFC vs. face recognition.

Where access control meets attendance

Most compliance risk hides in the seams between systems. If your door access control and your attendance software are separate products, the same person generates two sets of records that must be reconciled — and mismatches are exactly what an auditor flags. TimeClock 365 is the only platform that combines attendance management and door access control in a single cloud system: one badge event opens the door and records attendance at the same time, from one dataset. That is both simpler to run and easier to defend. Learn how the two connect in our guide to connecting door access to your attendance system, and why running them separately costs more.

Security is part of compliance

Regulators expect “appropriate technical and organizational measures.” In practice that means encryption in transit and at rest, role-based permissions, and independent certification. TimeClock 365 is certified to ISO/IEC 27001:2022, serves 3,000+ companies across 20+ countries in 12 languages, and stores every record in an access-controlled cloud — the kind of evidence auditors want to see. If you are still on local hardware, our cloud access control guide explains the move.

A short compliance checklist

Document your lawful basis and retention period.
Offer a non-biometric clock-in alternative.
Keep timestamps tamper-resistant with a correction audit trail.
Restrict record access by role and log every view.
Be able to export or delete an individual's data on request.
Choose an ISO 27001-certified provider.

Compliant time and attendance does not have to mean more admin. When records are accurate by design and access and attendance live in one place, staying compliant is the default rather than a monthly scramble. Start a free 14-day trial of TimeClock 365 and see how it works with your own team.