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GDPR legal basis capture and consent workflow on EU form submission

One of 565 written HubSpot workflow specs, by a collective of independent HubSpot consultants.

Professional

Seat pricing: Professional edition. To build it, a GTM Seat or an Ops Seat (an Ops Seat cannot create marketing emails or sequences). Per-hub plans: Marketing Hub Professional.

Contact7 stepsUpdated for HubSpot seat pricing
OutcomeEU-region contacts without a confirmed legal basis for marketing processing are held back from marketing sends and flagged for review, instead of silently entering nurture with no documented consent.
Workflow mapmarketing-ops-005
Contact created or legal basis changes leads to Country in EU/EEA/UK list?. Country in EU/EEA/UK list? leads to No: No action; Yes: Legal basis blank or unknown?. Legal basis blank or unknown? leads to Yes: Hold from marketing / non-marketing; No: Legal basis = Legitimate interest?. Hold from marketing / non-marketing leads to Add to EU consent review list. Add to EU consent review list leads to Notify marketing ops/compliance. Notify marketing ops/compliance leads to Create review task, due +2 business days. Legal basis = Legitimate interest? leads to Yes: Set annual review date; No, valid consent: Remove from review list, proceed. No Yes Yes No Yes No, valid consent Contact created or legal basis changes Country in EU/EEA/UK list? No action Legal basis blank or unknown? Hold from marketing / non-marketing Legal basis = Legitimate interest? Add to EU consent review list Set annual review date Remove from review list, proceed Notify marketing ops/compliance Create review task, due +2 business days
Contact created or legal basis changes leads to Country in EU/EEA/UK list?. Country in EU/EEA/UK list? leads to No: No action; Yes: Legal basis blank or unknown?. Legal basis blank or unknown? leads to Yes: Hold from marketing / non-marketing; No: Legal basis = Legitimate interest?. Hold from marketing / non-marketing leads to Add to EU consent review list. Add to EU consent review list leads to Notify marketing ops/compliance. Notify marketing ops/compliance leads to Create review task, due +2 business days. Legal basis = Legitimate interest? leads to Yes: Set annual review date; No, valid consent: Remove from review list, proceed. No Yes Yes No Yes No, valid consent Contact created or legal basis changes Country in EU/EEA/UK list? No action Legal basis blank or unknown? Hold from marketing / non-marketing Add to EU consent review list Notify marketing ops/compliance Create review task, due +2 business days Legal basis = Legitimate interest? Set annual review date Remove from review list, proceed

When to use it, when not to

Use it

  • Use when you sell into the EU/EEA/UK and your forms are configured with GDPR options (legal basis for processing, consent-to-process, consent-to-communicate, or legitimate interest).
  • Use this as a downstream compliance gate that reacts to what your forms already captured, not as the mechanism that captures consent itself. Legal basis and consent checkboxes are configured on the form and in account-level Privacy & Consent settings; a workflow cannot create consent that was never collected. (check in your portal: Settings > Privacy & Consent shows data privacy settings turned on, and each intake form has its GDPR options enabled)
Read more on when to use itShow less

Skip it

  • Do not use this to replace a Data Processing Agreement or legal review of your consent language. This is an operational safety net, not legal advice.
  • Do not apply it to non-EU contacts unless your policy applies GDPR-equivalent rules globally. Scope the country filter to your actual policy.
Read more on when to skip itShow less

The rest of this spec

Prerequisites · 5 items

Every property with its label, internal name, type and options, plus the assets the workflow needs.

Enrollment · 4 parts

The trigger, the criteria as ticked in the UI, the re-enrollment rule and the suppression list.

Steps · 7 numbered actions

Each action in order with its parameters, branches and delays.

Known pitfalls · 4

Traps seen in production, each with what breaks and what to do instead.

Test plan and UAT script · 5 cases, 3 variants

How to prove it works in a test portal, one case per branch, and a sign-off sheet.

Files · PDF, Markdown, JSON, CSV

The properties JSON creates the fields in one call. The workflow JSON documents the build.

Install · 1 click, switched off

The installer creates the properties and the workflow, switched off, then opens a task for what it cannot create. Nothing is deleted, enabled or enrolled.

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