Qualtrics Surveys and Data Protection – What Website Operators Need to Know

If a website operator uses Qualtrics Surveys, it processes survey data (survey results, user responses, contact information) for the purpose of collecting and analysing user feedback on the basis of legitimate interests (Art. 6(1)(f) GDPR) or consent (Art. 6(1)(a) GDPR). Qualtrics acts as a processor and stores data with the help of Standard Contractual Clauses (SCC) and possibly the Data Privacy Framework (DPF). This guide explains which information belongs in the privacy policy and which special features must be observed with Qualtrics.

A. Purpose and Function of Qualtrics

Qualtrics is a cloud-based survey and experience management platform with which website operators can carry out targeted surveys. The tool is typically integrated into the website via an iFrame, an embed code or a pop-up link. Qualtrics supports various functionalities:

• Online surveys: Creation and distribution of questionnaires to visitors
• Feedback widgets: Pop-ups or inline widgets for real-time capture of user feedback
• Contact management: Management of contact lists and respondent profiles
• Analytical evaluation: Real-time evaluation of survey results and trend analyses
• Integration: Coupling with CRM and analytics systems

The platform is operated by US-based Qualtrics LLC, but has an EU branch in Dublin, Ireland (Qualtrics Ireland Limited, One Clarendon Row, Dublin 2), which acts as EU data representative. The storage of customer data takes place on AWS infrastructure in the EU, unless the customer configures another region.

B. Mandatory Disclosures in the Privacy Policy on Qualtrics

Under the GDPR, a website operator must disclose in its privacy policy which data is processed (Art. 13(1)(a) GDPR), for which purposes (Art. 13(1)(c)), on which legal basis (Art. 13(1)(d)) and which categories of recipients (Art. 13(1)(e)). With Qualtrics, the following information is required:

• Purposes: Collection of user feedback, customer satisfaction measurement, user behaviour detection, product improvement
• Legal basis: Legitimate interests (Art. 6(1)(f) – if survey is not mandatory) or consent (Art. 6(1)(a)), if personal data is collected
• Recipients/Categories: Qualtrics LLC (USA) / Qualtrics Ireland Limited (EU), sub-processors
• Third-country transfers: Take place under Standard Contractual Clauses (SCC) and possibly EU-US Data Privacy Framework (DPF) – details see below
• Retention period: Depends on configuration; to be verified by the operator
• Data categories: See Section E

Important note: A tool-specific plug-and-play text template can lead to confusion, since Qualtrics has many functions and the legal bases can be different depending on the deployment scenario. A topic-oriented approach (e.g. section "Feedback and surveys") is better. The matterius generator helps you create such flexible formulations.

C. Provider of Qualtrics: Qualtrics LLC / Qualtrics Ireland Limited

Legal name (USA): Qualtrics LLC
Legal name (EU representative): Qualtrics Ireland Limited
EU address: One Clarendon Row, Dublin 2, Ireland
Country of seat (parent company): USA (California)
DPF status: Qualtrics is DPF-certified and has committed to comply with the EU-US DPF and Swiss-US DPF Principles. Important: Qualtrics currently relies primarily on Standard Contractual Clauses (SCCs), not on DPF – but DPF is additionally available.
Privacy Policy: https://www.qualtrics.com/privacy-statement/
DPA: Data Processing Agreement with Standard Contractual Clauses (SCCs) is integrated into the general terms and conditions (Terms of Service) and was updated to EU standard in 2021.
Law & jurisdiction: Under German and Irish law; dispute resolution before Irish courts

D. Data Processing by Qualtrics – Workflow

E. Data Collected when Using Qualtrics

Qualtrics collects a variety of data, depending on how the survey is configured. This data can be classified into the following standardised data class types:

• Web server log data: IP address, date/time/timezone, user agent, browser/OS/device
• User profiles: Username/identifier (if login required), e-mail address, login histories
• User content: Responses to survey questions, text input, ratings, comments
• Interaction data: Clicks on questions, time spent per question, drop-off points
• Technical telemetry data: Load times, errors, completeness of responses

Optionally, accessed URLs, referrers and other technical metadata can also be collected if the website operator has configured this.

F. Purposes of Use when Using Qualtrics

Qualtrics is primarily used for customer feedback and market research. This data can be classified into the following purpose classes:

• Communication: Direct collection of user feedback, customer surveys, customer satisfaction measurement
• General product improvement: Identification of improvement potential, identification of user wishes
• User profile creation: Segmentation of users by satisfaction, behaviour, demographics (if collected)
• General marketing: Identification of market trends, benchmarking against competitors
• Compliance: Documentation of customer feedback for quality assurance, internal audits

G. Legal Bases for Qualtrics

The legal basis depends on the deployment scenario:

1. Legitimate interests (Art. 6(1)(f) GDPR): If the survey serves to improve products and the user is not obliged to participate, a balancing of interests can take place. The user has an interest in good products; the company has a legitimate interest in feedback.

2. Consent (Art. 6(1)(a) GDPR): If personal data (e.g. e-mail, name) is collected, explicit consent is required.

3. Contract performance (Art. 6(1)(b) GDPR): In rare cases, when the survey is part of a contract.

To be examined on a case-by-case basis which legal basis applies and whether several have to be combined.

H. Special Features and Notes on Qualtrics

• DPF and SCC: Qualtrics is DPF-certified, but relies primarily on Standard Contractual Clauses (SCCs). The SCCs are integrated into the terms and conditions.
• Data transfer to the USA: A transfer of data to the USA is possible if Qualtrics technically requires this (e.g. for backup or analysis services). This is legally covered by SCC and possibly DPF.
• ISO 27001 certification: Qualtrics is ISO 27001 certified and is subject to FedRAMP authorisation.
• Data subject rights: Qualtrics supports data subject rights (export, erasure, rectification, portability) via its platform functions. However, the website operator must activate and document these.
• Details on retention period: The standard retention policy of Qualtrics should be clarified with the website operator.

I. FAQ on Qualtrics

J. Conclusion and Recommendation on Qualtrics

Qualtrics is a comprehensive feedback tool with solid GDPR documentation, Standard Contractual Clauses and DPF certification. For GDPR-compliant use, the following points are essential: (1) clear interpretation of the legal basis (legitimate interests or consent), (2) transparent disclosure in the privacy policy, (3) where applicable, obtaining consent for personal data, (4) review of the configured retention period.

Problematic: A tool-specific copy-paste text template from Qualtrics documentation. A topic-oriented approach is better that handles all survey tools (Qualtrics, Typeform, SurveySparrow etc.) under one roof and uses clear, comprehensible language. This information is based on provider information and publicly accessible sources (as of: 2026-04-22). Legal advice may be required in individual cases.