Digital Key Compliance and GDPR: What You Need to Know in 2025

Alexander Stasiak

Jul 24, 2025・6 min read

Digital key GDPRSmart lock compliance

Table of Content

📜 Why Compliance Matters for Digital Keys
🧱 6 GDPR Obligations for Digital Key Platforms
🔐 What Data Is Collected?
✅ How to Design a GDPR-Compliant Digital Key Platform
🧠 What About ISO 27001 & DORA?
🧠 Example: Privacy-First Feature Set
✅ Conclusion

Smart access systems and digital keys have become core components of modern infrastructure. But with great convenience comes great responsibility — especially when it comes to data protection and regulatory compliance.

If your digital key system stores access logs, identifies users, or transmits location data, you’re likely subject to GDPR, ISO 27001, or sector-specific regulations like DORA.

Let’s break down what you need to know.

📜 Why Compliance Matters for Digital Keys

Digital keys may seem "just technical," but in reality, they handle:

Personally Identifiable Information (PII)
User access logs (who, when, where)
Location metadata (via BLE, UWB, Wi-Fi)
Credential management (e.g. key shares)

That means you’re processing sensitive data, and regulators want to ensure:

It’s secured,
Logged,
Purpose-limited,
And consented to.

Obligation	What It Means in Practice
Lawful basis	Consent, contract, or legitimate interest for each data purpose
Data minimization	Don’t store more than you need — e.g. log events, not full location
User rights	Right to access, delete, or export digital key activity history
Security measures	Encryption, secure APIs, audit trails
Retention policies	Define how long access logs are stored, and when deleted
Breach reporting	Procedures in case of data leaks via app, lock, or admin dashboard

🔐 What Data Is Collected?

Most digital key systems store:

User identity (name, phone/email, device ID)
Access logs (timestamp, entry point, result)
Shared access history (who shared with whom)
Geo/proximity data (Bluetooth/UWB)
Lock interaction metadata (errors, retries)

Many of these are considered personal data under GDPR.

1. Privacy by Design

Build in data control and minimization from day one.

Ex.: Only log success/failure events — not location history unless strictly needed.

2. Consent Flows

Make sure users agree to the use of digital key logs, sharing, and notifications.

Tip: Use modular consent (checkboxes per data category) at onboarding.

3. Data Access & Deletion

Users must be able to view and delete their access logs.

Provide a privacy center inside the mobile/web app.

4. Encryption & Tokenization

All API requests, key handovers, and logs should be encrypted at rest and in transit.

Bonus: Use rotating tokens or session-based keys for added protection.

5. Data Processing Agreements (DPAs)

If your platform uses third-party lock vendors, cloud storage, or identity providers — ensure DPAs are signed.

e.g. AWS, Firebase, Noke, ROGER, SALTO

🧠 What About ISO 27001 & DORA?

ISO 27001: Requires formal controls for access, audit logs, user management, incident response
DORA (Digital Operational Resilience Act – EU): For finance-related platforms, requires robust ICT risk management, continuity, logging, and vendor oversight

If your digital key platform supports banks, logistics, smart buildings, or energy — you must consider these frameworks.

🧠 Example: Privacy-First Feature Set

Feature	Compliance Benefit
Access log export (CSV/JSON)	Supports data portability requests
Auto-log deletion after X days	Minimizes retention risk
Admin audit logs	Supports incident investigation
Consent screen with toggles	Verifiable consent collection
Role-based access control	Limits data visibility per role

✅ Conclusion

Digital keys enable powerful access flows — but also carry responsibility for user data. In 2025, platforms that embed compliance into their architecture will win both customer trust and regulatory peace of mind.

Don’t wait until an audit or breach to act. Build it right from the start.