GDPR Compliance in LCA Processes: Protecting Data While Measuring Impact

Life Cycle Assessment requires extensive data collection from across your value chain—suppliers, manufacturing partners, logistics providers, and sometimes even customers. When operating in or dealing with European entities, this data collection must comply with the General Data Protection Regulation (GDPR). Understanding where LCA and data protection intersect is essential for any organization conducting environmental assessments.

At first glance, LCA seems purely focused on environmental data: energy consumption, material flows, emissions. However, several aspects of LCA work can involve personal data:

Contact Information

Collecting supplier data typically involves contacting individuals. Names, email addresses, phone numbers, and job titles of supplier contacts are personal data under GDPR.

Small Business Data

For very small suppliers (sole proprietors, small partnerships), business operational data may be inseparable from personal data. Energy consumption of a one-person workshop is effectively personal data.

Expert Consultations

LCA practitioners often consult industry experts. Records of these consultations, including who said what, constitute personal data.

Audit Trails

EPD verification and ISO compliance require documenting who provided data, when, and through what process. These audit trails contain personal data.

Lawful Basis for Processing

You need a legal justification for collecting and processing personal data. For LCA work, the most relevant bases are:

Legitimate Interest: Your legitimate business interest in understanding environmental impacts can justify data processing, provided it doesn’t override individuals’ rights. Document your legitimate interest assessment.

Contractual Necessity: When data collection is part of a contractual relationship (e.g., supplier agreements requiring environmental data sharing), this provides a legal basis.

Consent: While possible, consent is generally not the best basis for B2B data collection due to the imbalance of power and difficulties with withdrawal.

Data Minimization

Collect only what you need. For LCA purposes:

Request aggregated data where possible (total facility energy, not individual machine readings)
Avoid collecting personal identifiers when anonymous data suffices
Don’t retain contact details longer than necessary for the project

Purpose Limitation

Data collected for LCA must be used for LCA purposes. If you want to use supplier environmental data for other purposes (marketing, benchmarking services to other clients), you need separate justification or consent.

Storage Limitation

LCA data may need to be retained for extended periods—EPDs are valid for 5 years, and ISO requires maintaining records. However, personal data within that dataset should be minimized or anonymized where possible.

Security

Environmental data shared by suppliers may be commercially sensitive. Implement appropriate technical and organizational measures to protect this data.

Practical Compliance Strategies

1. Design Data Collection Forms Carefully

Structure your data requests to separate:

Environmental/operational data (material quantities, energy use, emissions)
Contact information (for clarifications and verification)
Verification records (who provided what, when)

This allows you to retain necessary environmental data while deleting or anonymizing personal data sooner.

2. Use Data Processing Agreements

When working with LCA software providers, database providers, or external consultants, ensure Data Processing Agreements (DPAs) are in place. These should specify:

What personal data is processed
Processing purposes
Security measures
Sub-processor arrangements
Data deletion procedures

3. Implement Supplier Communication Protocols

When requesting data from suppliers:

Explain what data you need and why
Specify how long you’ll retain it
Clarify who will have access
Provide contact details for data protection queries
Include appropriate privacy notices

4. Anonymize Where Possible

For LCA databases and reporting:

Use supplier codes rather than names
Aggregate data across multiple suppliers
Remove identifying information from published results

5. Document Your Approach

Maintain records demonstrating GDPR compliance:

Data Protection Impact Assessments for large-scale LCA programs
Legitimate interest assessments
Records of processing activities
Data retention schedules

Special Considerations for Different LCA Types

Product LCAs

Typically involve fewer personal data concerns—most data relates to processes and materials rather than individuals. Main considerations are supplier contact management and verification records.

Organizational LCAs

May involve more extensive personal data, especially for service organizations where employee commuting, business travel, and work-from-home impacts are assessed. Ensure employee data collection has appropriate basis and transparency.

By definition involves assessing impacts on people—workers, communities, consumers. S-LCA has significant GDPR implications and requires careful design to ensure compliance while achieving assessment objectives.

International Data Transfers

LCA often involves global supply chains. When transferring personal data outside the European Economic Area, ensure appropriate safeguards:

Standard Contractual Clauses (SCCs) with suppliers
Assessment of destination country data protection adequacy
Supplementary measures where necessary

AI and Automated Processing in LCA

Increasingly, LCA involves AI-assisted data collection, gap-filling, and analysis. GDPR has specific provisions for automated decision-making:

Ensure transparency about where AI is used
Maintain human oversight of significant decisions
Document the logic involved in automated processing

At QuaLCA, our AI-supported processes are designed with GDPR compliance built in, ensuring efficiency gains don’t come at the cost of data protection.

For Occasional LCA Users

Include data protection clauses in consultant contracts
Ensure any LCA software providers have appropriate DPAs
Maintain basic records of data collected and from whom

For Regular LCA Practitioners

Develop standard data collection templates with privacy notices
Create data retention schedules for LCA projects
Train staff on GDPR implications of data collection
Implement secure data handling procedures

For Large-Scale Programs

Conduct Data Protection Impact Assessments
Appoint responsibility for data protection oversight
Implement privacy-by-design in LCA processes
Regular audits of compliance

Beyond avoiding fines (up to 4% of global turnover or €20 million), GDPR compliance in LCA brings benefits:

Supplier Trust: Demonstrating respect for data protection encourages suppliers to share better quality data.

Verification Readiness: Well-documented, properly managed data is easier to verify.

Reputation Protection: Environmental claims backed by GDPR-compliant processes are more defensible.

Efficiency: Good data governance reduces duplication and improves data quality.

QuaLCA’s Approach

Data protection is integral to our LCA services:

All client data handled under appropriate DPAs
GDPR-compliant data collection templates
Clear data retention and deletion policies
Staff trained in data protection requirements
Privacy-by-design in our processes

We help clients navigate the intersection of environmental assessment and data protection, ensuring LCA activities don’t create compliance risks.

Need guidance on GDPR-compliant LCA processes? Contact QuaLCA to discuss how we can help you assess environmental impacts while protecting personal data.

Explore our quality assurance services or find answers in our FAQ.

Where GDPR and LCA Overlap