TL;DR
Yes - SendGrid can be used in a GDPR-compliant manner, provided you follow all mandatory GDPR steps detailed below.
- How to maintain GDPR compliance with SendGrid
- Do I need a cookie banner with SendGrid?
- What does SendGrid’s GDPR policy says
- About SendGrid
How to maintain GDPR compliance with SendGrid
SendGrid is a cloud-based email delivery service that processes and stores personal data (such as email addresses and message content) on your behalf. This makes it a ‘data sub-processor’ under GDPR. Using certain SendGrid features, such as signup forms or email tracking, may require handling third-party cookies and additional user data.
Here’s how to ensure GDPR compliance when using SendGrid:
Request user consent (optional)
If you’re using SendGrid’s embeddable signup forms, open tracking, or click tracking features—which set cookies or log user-specific data—you must ask users for explicit consent.
Implement a “cookie opt-in banner” that clearly lists SendGrid and explains why cookies are set. Free Consent Management Platforms (CMPs) like Cookiebot or Termly can simplify this process.
Allow users to opt-out
GDPR requires that users can withdraw consent or opt out at any time. Ensure your CMP allows users to change their consent preferences easily, including opting out of email tracking or unsubscribing from marketing messages.
If you don’t use a CMP, provide accessible options (e.g. unsubscribe links, a privacy preference center, or direct opt-out links in your emails).
Add SendGrid to the list of data processors
You must list SendGrid as a data sub-processor in your privacy policy. Specify what data is transferred (e.g., email addresses, message content), why it’s processed (transactional/marketing/informational emails), and link to SendGrid’s privacy and data protection statements.
Example for Privacy Policy:
Third-Party Sub-Processors: We use SendGrid (Twilio) for email delivery and communications. Information such as your email address and message content may be transferred securely to SendGrid, whose privacy statement is available here. Data is processed solely for the purpose of communicating with you as per our stated purposes.
Monitor data security
According to Article 33 of GDPR, you must notify users promptly in the event of a data breach. Monitor your SendGrid account for any breach notifications. You’re also responsible for:
- Using strong authentication (passwords/MFA)
- Regularly reviewing your account’s access logs
- Following SendGrid’s security best practices
Respond to data subject requests
As the data controller, you must be ready to honor user requests (access, correction, deletion, or export of their data). SendGrid offers APIs and tools to help you locate or delete user data upon request.
Do I need a cookie banner with SendGrid?
Yes, if you use any SendGrid feature that sets cookies or tracks user behavior on your website (such as email tracking or forms). You must inform users and request consent via a cookie banner or consent platform. If you only use SendGrid for transactional email with no web tracking or cookies, a banner may not be necessary.
What does SendGrid’s GDPR policy says
Source: Twilio & SendGrid’s Trust Center
GDPR Commitment:
- Data Processor: SendGrid (as part of Twilio) acts as a processor for its customers, implementing proper technical and organizational measures to protect data integrity.
- Data Transfers: SendGrid supports lawful transfers of EU/UK/Swiss personal data to their U.S.-based servers via participation in the EU-U.S. Data Privacy Framework and the use of Standard Contractual Clauses (SCCs).
- Security and Certifications: SendGrid maintains robust security practices, including encryption, access controls, and certifications such as SOC 2, ISO 27001, and others.
- Processor Agreements: SendGrid offers a Data Processing Addendum (DPA) to help customers meet GDPR requirements.
Your responsibilities:
- Provide clear privacy notices and legal purposes for data collection
- Obtain all necessary user consents
- Configure SendGrid’s dashboard and features to minimize personal data processed and retained
- Respond to subject access requests and fulfill erase/rectification rights where applicable
Support and Documentation:
- Access logs
- API documentation for data management
- Compliance guides and DPA documents
- Dedicated support for privacy-related inquiries
About SendGrid
SendGrid, now a part of Twilio, is a trusted cloud-based email delivery platform serving both transactional and marketing email needs for organizations worldwide. Built for reliability, scalability, and deliverability, SendGrid helps automate communication for startups, enterprises, and everyone in between.
Key Features
- Reliable Email Delivery: Industry-leading infrastructure for sending transactional, notification, and marketing messages at scale—ensuring emails land in the inbox.
- Email API: Developer-friendly API for programmatic email sending, complete with customizable templates, scheduling, and analytics.
- Marketing Campaigns: Intuitive drag-and-drop builder for newsletters and campaigns, sophisticated segmentation, and A/B testing.
- Analytics: Real-time engagement reports and analytics to track opens, clicks, bounces, and unsubscribes, helping optimize future communications.
- Deliverability Tools: Authentication, feedback loops, dedicated IPs, and domain reputation tools to maximize inbox placement and protect sender reputation.
- Security: End-to-end security features, including 2FA/MFA, encrypted data at rest and in transit, and compliance certifications.
SendGrid is celebrated for its scalability, deliverability expertise, and developer-friendly tools, making it a leading solution for businesses sending critical communications.
Further Resources:
For questions about SendGrid’s data processing or specific GDPR needs, you can contact their privacy or compliance team via the links above.