CRM and GDPR
in Malta.

A CRM is simply an organised place for personal data: names, phone numbers, emails, WhatsApp chats, quotes, notes about what a customer wants. GDPR does not stop you keeping any of that. It asks five things of you. Know why you hold each piece of data and on what legal basis. Tell people what you do with it. Protect it, so only the right people see it. Keep it only as long as you need it. And let people see, correct or remove their data when they ask.

A good CRM makes all five easier than a spreadsheet or a phone full of chats, because everything sits in one place with a history. When a customer asks what you hold about them, you open one record instead of searching three phones, a laptop and an inbox. When a member of staff leaves, you switch off one login instead of hoping they delete a spreadsheet.

The common mistake is to treat “GDPR compliant” on a vendor’s website as the end of the job, then import every number from every staff phone, with no source, no basis and no end date. The vendor is responsible for its part; the decisions about your customers’ data are yours.

Marketing by email and SMS in Malta is covered by Subsidiary Legislation 586.01, alongside the GDPR. The rule is prior consent, with one exception, often called the soft opt-in: if you got someone’s email address when they bought from you, you may send them marketing about your own similar products or services, as long as you offered a simple, free way to opt out when you collected it and in every message after. A person who only enquired and never bought usually needs to give consent first.

WhatsApp has its own rules on top. Meta’s WhatsApp Business policies require people to opt in before you message them first, and marketing templates sent through the WhatsApp Business Platform are charged per message. Keep a separate consent field for each channel, email, SMS and WhatsApp, with the date and where it was given, because someone happy to receive appointment reminders may not want offers.

In the CRM, that means three practical things. Separate service messages, such as a booking confirmation, a reminder or the quote someone asked for, from marketing. Make unsubscribes flow back: when someone clicks unsubscribe in your email tool or types STOP on WhatsApp, the CRM record should update by itself. And keep a suppression list of people who opted out, so a later import does not add them back. The mistake we see most is a single “subscribed” tick that is meant to cover every channel and every kind of message.

Article 32 asks for security that fits the risk. In a CRM, most of that is settings. Give every person their own login, never a shared one. Turn on two-factor authentication. Set roles so that staff see what their job needs: a sales person sees their own leads, the office manager sees everything, the accounts person sees invoices but not private notes. Switch off a leaver’s access on their last day. Many small and family businesses in Malta share one password for years; it is the easiest thing on this list to fix.

Watch the free-text fields. Notes are where sensitive data creeps in: a copy of an ID card pasted into a note, a remark about someone’s health, a comment you would not want the customer to read. Remember that anyone can ask to see what you hold about them. Write notes as if the customer will read them, and keep ID documents in a restricted file area, not in the notes.

Limit exports too. Every spreadsheet downloaded from the CRM is a copy outside your controls, often emailed around and never deleted. If your CRM can restrict exports to managers and keep an audit log of who viewed or downloaded what, use it.

People have the right to see the data you hold about them, to have it corrected, to have it deleted in many cases, to object to marketing and to take their data elsewhere. You must reply without undue delay and within one month, which you can extend by two further months for complex requests if you tell the person within the first month. Requests do not need a special form. A message on Facebook, an email to a staff member or a WhatsApp saying “please delete my details” counts.

A CRM turns these from a hunt into a routine. Open the record, export what it holds, including notes, messages and files, and send it. For deletion, delete in the CRM and in every connected tool, and log that you did it. Keep a short request log with the date received, what was asked and the date you replied, so you can show you met the deadline.

Train whoever answers your messages to spot a request and pass it on the same day. In a small business the risk is not refusing a request; it is the message sitting unread in someone’s phone for six weeks.

A childcare and nanny agency came to us with bookings, nanny applications, documents and payments spread across messages, spreadsheets and email. We designed one platform with three connected parts: a command centre for the office, a portal where nannies apply and accept job offers, and a booking app for parents. Each side sees only what it needs: parents see their own bookings, nannies see their own offers and documents, and the office sees everything.

It is a new system, so we do not publish results or usage figures for it. It shows the point of this article in practice: when roles and permissions are designed in from the start, data protection becomes part of how the system works rather than a policy nobody reads.

Want a CRM where every person sees only what they should? Message us on WhatsApp ↗

We start by mapping your data: where enquiries and customers come from, which tools they pass through, who needs to see what and how long you need each type of record. Then we build that into the CRM, whether it is a ready-made one we set up or a custom system: source and basis fields, consent per channel, roles, EU hosting, retention views, export and deletion that reach every connected tool, and opt-outs that sync by themselves.

We are not lawyers, and we will tell you when a question needs one, such as the wording of your privacy notice or a sector rule. What we do is make the system follow the rules you set, so your team does not have to remember them. Custom CRM systems start from €7,500, excluding VAT. See the CRM page for what is included, and our CRM cost guide for how projects are priced.