Social media data collection is a routine part of how organisations engage with customers, promote services, and analyse performance. But in doing so, they often handle personal data, including names, locations, preferences, and even behaviour. Most organisations in healthcare, finance, education, retail, or government use platforms such as LinkedIn, Instagram, TikTok, and Facebook more. This means they are almost certainly handling personal data.
Data protection laws such as the GDPR and the Privacy and Electronic Communications Regulations (PECR), along with, where relevant, the EU AI Act, is mandatory for compliance. These rules govern how you collect, store, share, and protect personal data, especially when AI tools are involved.
From my experience as a Data Protection Officer,
many organisations underestimate these responsibilities. It is not just about what you post or share, you need to manage the entire data lifecycle- from collection through to deletion, and understand the risks if things go wrong. Get it wrong, and you could face hefty fines, damaged reputation, and loss of trust.
If your organisation uses social media, this article offers practical advice on meeting your data protection and privacy obligations. Based on real-world policy reviews, audits, training, and compliance work, it will help you keep your data safe and your organisation compliant.
What Counts as Customer’s “Personal Data” on Social Media?
Pretty much anything that can identify someone:
- Comments and direct messages
- Names, profile images, and handles
- Data collected via promotions or giveaways
- Behavioural data from tracking pixels or ad analytics
This data is subject to the same rules as any other under the GDPR or other applicable data laws.
Lessons of Non-Compliance
Facebook Pixel used without consent:
A UK retailer was caught using Facebook’s tracking pixel on their website without telling visitors or gaining proper consent. The ICO issued a warning and ordered the business to stop processing data collected unlawfully.
Dutch platform fined €725,000 for not deleting user data:
A social media platform in the Netherlands failed to let users delete their profiles easily, breaching GDPR’s right to erasure. The Dutch DPA imposed a significant fine.
Meta fined €1.2 billion:
Meta (Facebook) was fined by the Irish Data Protection Commission for transferring European users’ data to the US without sufficient safeguards. Although large-scale, it is a clear warning, even well-known platforms aren’t exempt from rules.
These examples show that regulators are watching, and breaches even if unintentional, can have serious consequences.
Social Media Data Collection Checklist for Compliance
Here is what I recommend every organisation does:
1. Know Your Platforms and Data
Make a list:
- What platforms you use
- What data is collected (DMs, likes, comments, contact info from competitions)
- Whether you’re using tools like pixels, trackers or third-party campaign apps
2. Have a Legal Basis
Ask yourself: do you really need all the data you are collecting?
- Use consent for competitions or newsletters
- Legitimate interest may apply for some analytics, but document it properly
- Always avoid collecting sensitive personal data unless strictly necessary
3. Keep Your Privacy Policy Honest & Clear
Your privacy notice should:
- Include details about social media activity
- Say how data is collected, what it’s used for, who it’s shared with
4. Review Third-Party Tools
Any scheduling tools or analytics platforms connected to your socials?
- Check they comply with GDPR or your local equivalent
- Review their privacy terms and make sure you’ve got a contract with data protection clauses
5. Control Access
- Use two-factor authentication (2FA) on social accounts
- Only give access to staff who really need it
- Remove access when people change roles or leave
6. Train Your Team
Train staff on:
- What they can and can not share
- How to spot risky posts or breaches
- Who to contact internally if something goes wrong
7. Be Ready for Data Requests
If someone asks for their personal data or wants it deleted:
- You need a process to respond quickly and lawfully
- Social media data is still personal data, even if it is public-facing
Final Thoughts from a DPO
Social media data isn’t just a marketing tool, it is part of your organisation’s personal data mapping, and if you are not treating it with care, you are exposing your business to avoidable risks.
In my work, I ask questions such as:
- Are you aware of what your tools are doing in the background?
- Are staff trained on data risks?
- Is social media included in your privacy notices, data map, and data protection training?
Take Action Before It Is Too Late!
Let us help you go beyond the checklist and create a comprehensive compliance roadmap, including employee training, audits, policy reviews, and advice tailored to how your business uses data. Whether you are just getting started or need a full privacy health check, we will make sure your social media presence is as compliant as it is creative.
Written by
Lynsey Hanson | Global Data Protection Officer