# GDPR for website forms: what each type of form needs

Contact, quote, newsletter, job application, checkout, health and children's forms: the lawful basis, consent box, notice and retention each one needs.

Author: Formgong
Published: 2026-10-19
Language: en
Canonical: https://formgong.com/en/blog/gdpr-form-types/

Every form needs a lawful basis chosen before it goes live, a short notice at the form (Art. 13), only the fields you need (Art. 5(1)(c)) and a deletion date. Forms that answer a request, such as a contact, quote or booking form, usually rely on Art. 6(1)(b) or (f) and need no consent checkbox. Newsletters, optional extras and sensitive data need consent: a separate box that starts unticked and does not block the form.

## Five things every form has to settle

Whatever a form asks for, the same five questions come up. Answer them once for each form on your site, then write the answers into your privacy policy.

- Why you collect the data and on which lawful basis. Art. 6(1) GDPR lists six bases, and website forms almost always use one of four: consent (a), a contract or steps the person asked for before one (b), a legal obligation (c), or your legitimate interests (f). Choose before the form goes live. The EDPB says a controller cannot switch from consent to legitimate interest later because the consent turned out to be invalid (Guidelines 05/2020, paras 121 to 123).

- What you tell people at the form. Art. 13 lists what they must learn when you collect the data: who you are, the purpose and basis, who receives the data, any transfer outside the EEA, how long you keep it, their rights, and whether they have to give it.

- Which fields you need. Art. 5(1)(c) says data must be "limited to what is necessary" for the purpose. Every extra field is one more thing to explain, protect and delete.

- When you delete it. Art. 5(1)(e) forbids keeping data longer than the purpose needs, and Art. 13(2)(a) makes you state the period or how you decide it.

- Who else handles it. A form backend, email service or CRM that stores submissions for you is your processor, and Art. 28(3) requires a contract with it. If any of them moves data outside the EEA, Chapter V (Art. 44 to 49) applies as well.

A consent checkbox belongs only on forms where consent is the basis for that part of the processing. When it is, four rules apply. The box starts empty: Recital 32 says "silence, pre-ticked boxes or inactivity" are not consent, and in Planet49 (C-673/17, 1 October 2019) the EU Court of Justice held that a pre-ticked box the user has to untick does not give valid consent. The request has to be clearly separate from other text (Art. 7(2)). The form must not refuse to send because the box is empty when the data is not needed for what the person asked (Art. 7(4) and Recital 43). And withdrawing has to be as easy as agreeing (Art. 7(3)).

Use one box per purpose. In the EDPB's own example, a single box for marketing emails and for sharing details with other group companies is not valid consent for either (Guidelines 05/2020, para 45).

## Form by form: the short version

This is the usual starting point. Your facts can change the answer, so read the section for each form below.

GDPR for 14 common website forms
FormUsual lawful basisConsent checkboxDelete when

Contact formArt. 6(1)(f); (b) for questions about your servicesOnly for marketing extrasThe conversation is over, plus a short follow-up period
Quote, booking or appointmentArt. 6(1)(b)NoNo contract follows; otherwise it becomes a customer record
Newsletter or marketing sign-upArt. 6(1)(a), plus national e-marketing rulesYes, unless the whole form is the sign-upThe person unsubscribes
Account or registrationArt. 6(1)(b)Only for extras such as marketingThe account is closed
Job application with CVArt. 6(1)(b); national employment lawOnly to keep the CV for future rolesThe hiring round ends, plus the period for claims
File uploadSame as the form it is part ofNo extra boxWith the submission
Order, checkout, invoiceArt. 6(1)(b); (c) for tax recordsOnly for marketingAfter delivery and returns; invoices when tax law allows
Feedback or reviewArt. 6(1)(f); decide separately for publishingFits when publishing is optionalYou stop showing or using it
SurveyArt. 6(1)(f) or (a)If you rely on consentThe analysis is done; anonymise sooner if you can
Event registrationArt. 6(1)(b)For sharing with sponsors or partnersAfter the event and its paperwork
Health and other Art. 9 dataArt. 6(1) basis plus an Art. 9(2) conditionExplicit consent, if that is the conditionAs early as care and law allow
Forms used by childrenAs above; Art. 8 when consent is used for an online serviceParent's consent under 16, or the national ageAs for the form type
B2B lead formArt. 6(1)(f) or (b)For marketing emails where national law asksThe lead goes cold
Tracking, analytics, embedsePrivacy Art. 5(3) for the device; GDPR for the dataYes, cookie consentPer tool; state the cookie lifetime

## Contact form

Someone writes to you and you reply. Your legitimate interest in answering and keeping the correspondence (Art. 6(1)(f)) covers most messages. When the message asks about your services, the EDPB says replying can rest on Art. 6(1)(b), because the person is taking a step towards a possible contract (Guidelines 2/2019, para 46). If you rely on (f), Art. 13(1)(d) makes you name the interest in your notice.

No consent box is needed to answer. Add one only if you want to send marketing as well, and keep it optional. Name, email and the message are enough for most sites. Ready notice text and a copyable form are in our [GDPR contact form template](/en/blog/contact-form-gdpr/).

## Quote, booking and appointment requests

The person asks for a price, a restaurant table, a slot at the hairdresser or a call with a plumber. That is a step at their request before a contract, so Art. 6(1)(b) fits even if they never book (Guidelines 2/2019, paras 45 and 46). The EDPB gives a small example: someone types a postal code to see if a company serves their area, and that processing also falls under (b).

The same paragraph has a limit. Art. 6(1)(b) does not cover "unsolicited marketing" or anything done only on your initiative (para 47). If you want to keep the address for offers later, that is a separate purpose with its own basis. Ask only for what the quote or booking needs. A phone number can be optional when email works, and a date of birth rarely belongs on a booking form.

Once the person books, the data becomes part of the contract. When the work is done, invoices and accounting records usually stay for as long as national tax law requires, and that retention rests on Art. 6(1)(c) (Guidelines 2/2019, example 4).

```html
<style>
  .fg-form label { display: block; margin: 0 0 12px; }
  .fg-form input:not([type="checkbox"]), .fg-form textarea { display: block; width: 100%; box-sizing: border-box; margin-top: 4px; padding: 10px; font: inherit; }
  .fg-form textarea { min-height: 120px; }
  .fg-form small { display: block; margin-top: 10px; opacity: .75; }
</style>
<form class="fg-form" action="https://formgong.com/submit" method="POST">
  <input type="hidden" name="access_key" value="fk_your_access_key">
  <input type="hidden" name="_lang" value="en">
  <input type="hidden" name="_subject" value="New quote request">
  <label>Name <input type="text" name="name" autocomplete="name" required></label>
  <label>Email <input type="email" name="email" autocomplete="email" required></label>
  <label>Phone <input type="tel" name="phone" autocomplete="tel"></label>
  <label>What do you need? <input type="text" name="service" required></label>
  <label>Preferred date (optional) <input type="text" name="preferred_date"></label>
  <label>Details <textarea name="message"></textarea></label>
  <div aria-hidden="true" style="position:absolute;inset-inline-start:0;top:0;width:1px;height:1px;overflow:hidden;clip-path:inset(50%)">
    <label>Leave this field empty<input type="text" name="botcheck" tabindex="-1" autocomplete="off"></label>
  </div>
  <button type="submit">Send</button>
  <small>We use these details to prepare your quote and, if you book, to carry out the job. Phone is optional. Details: <a href="/privacy-policy">privacy policy</a>.</small>
</form>
```

## Newsletter and marketing sign-ups

Email marketing has two sets of rules. The GDPR decides the lawful basis, and Art. 13(1) of the ePrivacy Directive says email marketing needs the recipient's prior consent. Each EU country writes that directive into its own law, so the details differ. There is one common exception in Art. 13(2): a business that got a customer's email address while selling them something may email them about its own similar products, if the customer could refuse when giving the address and can refuse in every message.

When consent is the basis, the request must say who you are, what you will send and that people can withdraw (Guidelines 05/2020, para 64). Art. 7(1) means you must be able to show that each person agreed, so store the date, the form and the wording they saw. A confirmation email is not named in the GDPR, but it is a common way to have that proof. Unsubscribing has to be as easy as signing up (Art. 7(3)), and Art. 21(3) says marketing stops once someone objects.

A form whose only job is the newsletter does not need a checkbox on top of the Subscribe button. Recital 32 accepts conduct that "clearly indicates" agreement, and pressing Subscribe under a clear sentence does that. A checkbox is needed when the newsletter rides along on another form, such as a contact or order form. Then it must be optional and start unticked.

```html
<style>
  .fg-form label { display: block; margin: 0 0 12px; }
  .fg-form input:not([type="checkbox"]), .fg-form textarea { display: block; width: 100%; box-sizing: border-box; margin-top: 4px; padding: 10px; font: inherit; }
  .fg-form textarea { min-height: 120px; }
  .fg-form small { display: block; margin-top: 10px; opacity: .75; }
</style>
<form class="fg-form" action="https://formgong.com/submit" method="POST">
  <input type="hidden" name="access_key" value="fk_your_access_key">
  <input type="hidden" name="_lang" value="en">
  <input type="hidden" name="_subject" value="Newsletter sign-up">
  <label>Email <input type="email" name="email" autocomplete="email" required></label>
  <div aria-hidden="true" style="position:absolute;inset-inline-start:0;top:0;width:1px;height:1px;overflow:hidden;clip-path:inset(50%)">
    <label>Leave this field empty<input type="text" name="botcheck" tabindex="-1" autocomplete="off"></label>
  </div>
  <button type="submit">Subscribe</button>
  <small>Subscribe to get our monthly newsletter by email. You can unsubscribe with the link in every issue. Details: <a href="/privacy-policy">privacy policy</a>.</small>
</form>
```

## Account and registration forms

Creating an account the person asked for is performance of a contract, Art. 6(1)(b). The contract covers what the account needs: login details, the service itself, billing if it is paid. The EDPB does not accept (b) for usage metrics or for improving the service, because the service could run without them (Guidelines 2/2019, paras 48 and 49). Those need legitimate interest or consent, and marketing needs its own basis as above.

Plan for closure on day one. When the contract ends, processing for it should stop, and records you keep for legal reasons must have a basis and a period you announced from the start (Guidelines 2/2019, paras 41 and 43).

## Job applications with a CV

Applying for a job is a step towards an employment contract at the applicant's request, so Art. 6(1)(b) is the usual basis. Art. 88 lets each EU country add its own rules for recruitment, so check the employment data rules where you hire.

Consent is a poor basis here. The EDPB says consent between employers and staff, current or future, is rarely free because people fear what happens if they refuse (Guidelines 05/2020, paras 21 and 22). It also says consent can work when refusing has no consequences. An optional box to keep the CV for future roles is that kind of case, as long as it has no effect on the current application.

CVs carry more than you ask for. People add photos, dates of birth, health details or religion. Say on the form what you want and what to leave out, because Art. 9 data needs its own condition. Criminal record information is covered by Art. 10 and is only allowed where the law authorises it. For retention, the UK regulator gives a useful rule of thumb: without a clear business reason, do not keep records of unsuccessful applicants beyond the period in which they could bring a claim about the recruitment (ICO, storage limitation guidance).

```html
<form action="https://formgong.com/submit" method="POST" enctype="multipart/form-data">
  <input type="hidden" name="access_key" value="fk_your_access_key">
  <input type="hidden" name="_lang" value="en">
  <input type="hidden" name="_subject" value="Job application">
  <label>Name <input name="name" autocomplete="name" required></label>
  <label>Email <input type="email" name="email" autocomplete="email" required></label>
  <label>Role you are applying for <input name="role" required></label>
  <label>CV (PDF)
    <input type="file" name="attachment" accept="application/pdf,.pdf" required>
  </label>
  <label>
    <input type="checkbox" name="talent_pool" value="yes">
    Keep my application for 12 months and contact me about other roles. This does not affect this application.
  </label>
  <p>We use your application to assess it for this role. Please leave out health details, photos and other
    information we did not ask for. More in our <a href="/privacy-policy">privacy policy</a>.</p>
  <div aria-hidden="true" style="position:absolute;inset-inline-start:0;top:0;width:1px;height:1px;overflow:hidden;clip-path:inset(50%)">
    <label>Leave this field empty <input type="text" name="botcheck" tabindex="-1" autocomplete="off"></label>
  </div>
  <script src="https://challenges.cloudflare.com/turnstile/v0/api.js" async defer></script>
  <div class="cf-turnstile" data-sitekey="YOUR_TURNSTILE_SITE_KEY"></div>
  <button type="submit">Send application</button>
</form>
```

## File uploads

An upload has the purpose and basis of the form it sits on, so it does not need a separate checkbox. It does carry more risk. A file can hold anything: a scanned ID, a photo of an injury, a whole CV. Restrict the file types and sizes to what the purpose needs (Art. 5(1)(c)), keep the files private, and delete them with the submission. Art. 32 asks for security that matches the risk, and a folder of public file links does not meet that.

In Formgong, uploads accept PDF, PNG and JPEG only. Every file is virus-scanned, stored privately in the EU and deleted together with its submission. The details and the code are in [contact form with file upload](/en/blog/contact-form-with-file-upload/).

## Orders, checkout and invoices

Delivering what someone bought is the textbook case for Art. 6(1)(b). The EDPB names the delivery address and card details as data that is necessary for an online purchase (Guidelines 05/2020, para 30). Keeping invoices because tax law requires it is Art. 6(1)(c).

Consent rules come in with the extras added to checkout. Sharing the buyer's details with partners or signing them up for offers is not needed for the sale, so it cannot be a condition of buying (Art. 7(4)). The ICO gives this exact example: a furniture shop that makes consent to share data with other stores part of checkout does not get valid consent. For your own similar products, the ePrivacy soft opt-in described under newsletters may apply, with an opt-out at checkout and in every email.

## Feedback and review forms

Private feedback about your service, read by you and your team, fits legitimate interest (Art. 6(1)(f)). Publishing a review is a different purpose because it puts the person's words and often their name in public. Decide the basis for publishing before you collect, tell people at the form that the review will be public, and let them choose how their name appears. A first name and an initial are usually enough, and that keeps to data minimisation. If publishing is optional for the person, consent fits well and has to be as easy to withdraw as it was to give.

If you build on Art. 6(1)(f) instead, the person can object under Art. 21(1), and you need a plan for taking a review down.

## Surveys

Truly anonymous answers are outside the GDPR: Recital 26 says the rules do not apply to information that no longer relates to an identifiable person. In practice survey data is rarely that clean. Free-text answers name people, small groups make answers traceable, and the survey tool may log IP addresses. Treat the survey as personal data unless you have checked.

For feedback from your own customers, legitimate interest often works. For research where taking part is optional and the questions go deeper, consent is the clearer basis. Either way, say in the notice what you collect and when you will delete or anonymise the answers.

## Event registration

Registering someone for an event they asked to attend is Art. 6(1)(b). Two parts need care. Dietary or access needs can reveal health or religion, which are Art. 9 categories, so ask only what the venue needs and make those fields optional. And sharing the attendee list with sponsors is a separate purpose that needs its own optional consent, naming the companies (Guidelines 05/2020, para 45).

## Health and other sensitive data (Art. 9)

Art. 9(1) prohibits processing health data, data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic and biometric data, and data about sex life or sexual orientation. You need an Art. 6(1) basis and one of the exceptions in Art. 9(2). For a website form that is usually explicit consent (Art. 9(2)(a)), or, for doctors and clinics, the provision of health care under national law by professionals bound by secrecy (Art. 9(2)(h) and 9(3)). Art. 9(4) lets member states add conditions for health data.

Explicit consent means an express statement. The EDPB's example is a screen with Yes and No boxes and wording such as "I, hereby, consent to the processing of my data" (Guidelines 05/2020, paras 93 and 96). Small businesses lose one exemption here too. The rule that firms with fewer than 250 staff need not keep records of processing does not apply when they process Art. 9 data (Art. 30(5)).

Think about where the data ends up. A notification email that copies the whole message puts the details in every inbox it reaches, which matters for Art. 32 security. In Formgong you can set a form to "Don't keep", which deletes what people wrote once it has been delivered, usually within 10 minutes.

## Forms used by children (Art. 8)

Art. 8 applies when two things are both true: consent is the basis, and you offer an online service directly to a child (Guidelines 05/2020, para 127). Then a child under 16 cannot consent alone, and a parent has to give or authorise it. Member states may lower that age, but not below 13, so the age depends on the country. You have to make reasonable efforts to check that the parent really consented. For low-risk cases the EDPB says checking by email may be enough (paras 125 and 136).

Even outside Art. 8, children's interests weigh more in a legitimate interest test (Art. 6(1)(f)), and Recital 38 singles out marketing and profiling. Write the notice in words the child can follow (Art. 12(1) and Recital 58).

## B2B lead forms

The GDPR protects people. A work email such as jane.doe@company.com identifies Jane, so it is personal data (Art. 4(1)). A demo request or a sales enquiry fits Art. 6(1)(b) or (f) in the same way as a contact form.

Two habits need care. If you add data about the lead from other sources, such as a job title from a database, Art. 14 obliges you to tell the person, because that data did not come from them. And if the form offers a guide or webinar and you also want to send sales emails, ask for that separately. Under Art. 7(4) consent is presumed not freely given when the download depends on agreeing to something it does not need. Whether email marketing to business addresses needs consent depends on national ePrivacy law.

## Tracking, analytics and third-party embeds

Cookies and similar technologies follow a different law. Art. 5(3) of the ePrivacy Directive requires consent before anything is stored on or read from the visitor's device, unless it is strictly necessary for a service the visitor asked for. Planet49 applied this to a pre-ticked cookie box and added that people must be told how long cookies last and whether third parties can access them. Consent under that rule must meet the GDPR standard (Guidelines 05/2020, footnote 27).

So a cookie banner and a form notice do different jobs, and one does not replace the other. Watch for tools that record a visitor's form input before they press Send, such as session replay scripts, and for embedded forms, maps or captchas loaded from another company's servers. Each of them belongs in your cookie notice and, if it receives form data, in your privacy policy as a recipient.

## Processors, contracts and transfers outside the EEA

Every service that stores or forwards submissions for you is a processor. Art. 28(3) requires a written contract that, among other things, limits it to your instructions and makes it help you answer access and deletion requests. Under Art. 28(2) it may only bring in sub-processors with your authorisation, and must tell you about changes. Processors do not have to be named in a consent request, but your privacy notice must list recipients or categories of recipients under Art. 13(1)(e) (Guidelines 05/2020, para 65).

If a processor sends data outside the EEA, the transfer needs a basis under Chapter V, for example an adequacy decision or standard contractual clauses (Art. 46(2)(c)), and the notice must say so (Art. 13(1)(f)). Check chat apps used for notifications and AI features in particular. Our [GDPR form backend checklist](/en/blog/gdpr-form-backend/) goes through what to look for in a form service.

For Formgong, submissions are stored in the EU, a data processing agreement under Art. 28 is part of the terms, and the [where data is stored](/en/data/) page lists the optional features, such as Telegram delivery, that can process data outside the EU.

## Setting up these forms with Formgong

Every example above posts to the same Formgong endpoint, so one account covers a contact form, a quote form and a job application. To connect a form on your own site, follow the step-by-step guide for your platform in the [Formgong docs](/en/docs/): [plain HTML](/en/docs/html/), [WordPress](/en/docs/wordpress/), [Wix](/en/docs/wix/), [Shopify](/en/docs/shopify/) and AI builders such as [Lovable](/en/docs/lovable/). Submissions go to email and one inbox, and each form has its own retention setting: 30 days on the free plan, or "Don't keep" for forms that should not store anything after delivery. Our [free website templates](/en/website-templates/) come with the form already connected, and the [help chat](/en/docs/help-chat/) answers visitors' questions from your own pages.

This article is general information, not legal advice. National laws add rules, especially for marketing, employment and health, so have a lawyer or your data protection officer check anything you are unsure about.

Did we miss a form you run, or does your country handle one of these differently? Write to support@formgong.com and tell us. We read every message and update the guide.

## Frequently asked questions

### Does every website form need a GDPR consent checkbox?

No. A checkbox is needed only where consent is the lawful basis, for example a newsletter added to a contact form. Contact, quote, booking, order and account forms usually rely on Art. 6(1)(b) or (f) and need a clear notice at the form instead.

### Can a GDPR consent checkbox be pre-ticked?

No. Recital 32 says pre-ticked boxes are not consent, and the EU Court of Justice confirmed it for a pre-ticked box in Planet49 (C-673/17). The box must start empty and the person must tick it.

### Can I make a consent checkbox required to send the form?

Not when the data is not needed for what the person asked. Art. 7(4) presumes such consent is not freely given. A quote request must work without the marketing box.

### How long can I keep form submissions?

The GDPR sets no number. Keep data only as long as the purpose needs (Art. 5(1)(e)), state the period in your notice (Art. 13(2)(a)) and delete on schedule. Tax law may require keeping invoices longer.

### Is a cookie banner enough for my forms?

No. Cookie consent covers storing and reading data on the device under the ePrivacy Directive. What people type into a form is covered by the GDPR and needs its own notice at the form.

## Sources and documentation

- [GDPR, Regulation (EU) 2016/679 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2016/679/oj)
- [ePrivacy Directive 2002/58/EC, consolidated (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002L0058-20091219)
- [CJEU, Planet49, C-673/17 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62017CJ0673)
- [EDPB Guidelines 05/2020 on consent](https://www.edpb.europa.eu/system/files/documents/files/file1/edpb_guidelines_202005_consent_en.pdf)
- [EDPB Guidelines 2/2019 on Art. 6(1)(b)](https://www.edpb.europa.eu/sites/default/files/files/file1/edpb_guidelines-art_6-1-b-adopted_after_public_consultation_en.pdf)
- [ICO: What is valid consent?](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/consent/what-is-valid-consent/)
- [ICO: Storage limitation](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-protection-principles/a-guide-to-the-data-protection-principles/storage-limitation/)
- [Where Formgong stores data](https://formgong.com/en/data/)

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