The moment you put a contact form on your website and a visitor from Germany, France or Poland fills it in — you are processing personal data subject to GDPR. Most freelancers either ignore this entirely or go overboard with complex consent management platforms designed for enterprise. Here is what you actually need as a small IT service provider.
Does GDPR apply to you?
Yes, if any of these are true:
- You have a website accessible to EU residents
- You have a contact form that collects name or email
- You use Google Analytics, Meta Pixel, or any marketing cookie
- You send newsletters or marketing emails to EU subscribers
It does not matter that you are based in Georgia, Ukraine or anywhere outside the EU. GDPR follows the data subject (the visitor), not the business location.
The minimum viable compliance setup
For a freelancer offering services and collecting only contact form submissions, here is the realistic minimum:
Minimum GDPR checklist
- Privacy Policy page — who you are, what data you collect, why, how long you keep it, user rights
- Link to Privacy Policy in your footer (every page)
- Contact form — add a checkbox "I agree to the Privacy Policy" OR a visible notice near the submit button
- Cookie notice — if you use any non-essential cookies (analytics, tracking), you need consent before setting them
- If you use NO tracking cookies — a simple informational banner is enough (no "Accept/Reject" needed)
- Terms of Service — defines the contract, payment, liability, governing law
What you can skip (as a small freelancer)
- Full CMP (Consent Management Platform) — tools like Cookiebot cost $10–50/month and are overkill if you have no analytics
- Data Processing Agreement (DPA) with clients — only needed if you process your client's customer data on their behalf. If you just build a website, it's not required
- DPO (Data Protection Officer) — only mandatory for large-scale data processors
- GDPR registration — most EU countries don't require individual freelancers to register with their DPA
The "no tracking" advantage
The cleanest GDPR setup is simply: use no third-party tracking at all. No Google Analytics, no Facebook Pixel, no Hotjar. Then your cookie situation is trivial — you may use only strictly necessary functional cookies (like a language preference or session cookie) without needing consent at all (GDPR Recital 25, ePrivacy Directive Art. 5(3)).
If you want analytics, use a privacy-respecting self-hosted alternative like Plausible (no cookies, no personal data) — then you still don't need a consent banner.
Privacy Policy — what to include
At minimum, your Privacy Policy should state:
- Who is the data controller (your name, legal entity, country, contact)
- What personal data you collect (name, email, IP address)
- Legal basis for each type (consent, legitimate interest, contract performance)
- How long you keep data
- User rights: access, rectification, erasure, portability, objection
- How to exercise rights (your email address)
- Right to complain to a supervisory authority
Terms of Service — why they matter for freelancers
Terms of Service is your contract with clients. Without it, a dispute defaults to the consumer protection laws of the client's country (which can be very favourable to consumers and unfavourable to you). With a proper ToS that specifies Georgian law as governing, you have a clear framework.
Note: for EU consumer clients (B2C), mandatory consumer protection rights still apply regardless of your ToS. For B2B clients (companies), your governing law clause is much stronger.
Summary
For a freelance web developer with no tracking tools and a simple contact form: add a Privacy Policy page, link it in the footer, put a note near your contact form, and write a Terms of Service page. That is genuinely all you need to operate legally with EU clients. The entire setup takes one afternoon — and I already have templates ready on this site.