GDPR changes in payroll: What employers need to prepare for in 2025

Since its introduction on 25 May 2018, the General Data Protection Regulation (GDPR) has reshaped how organisations handle personal data across Europe and the world. It replaced outdated legislation, such as Ireland’s Data Protection Acts of 1998 and 2003, bringing data protection in line with the needs of modern technologies like cloud computing and AI.  

For organisations in Ireland, 2025 introduces fresh compliance priorities, particularly as remote work and cross-border employment become the norm. Employers must not only adhere to GDPR but also ensure that specific practices, like processing travel expenses in payroll, meet compliance standards. 

GDPR and travel expense compliance  

The GDPR applies to any organisation processing the personal data of EU citizens, regardless of its location. When it comes to travel expense payroll in Ireland, the regulation ensures that any data relating to employee claims, such as civil service mileage rates for 2025, is handled securely. 

What is personal data? 

Under GDPR, personal data includes: 

• Employee travel claims: Information such as names, destinations, and mileage rates. 
• Bank details: Used for reimbursement purposes. 
• Travel documentation: Receipts or records of incurred business travel costs. 

Organisations must retain this data for as long as necessary but no longer, adhering to GDPR’s storage limitation principle. 

Employer obligations when managing employee travel reimbursement 

When handling travel-related data for payroll, businesses in Ireland must be particularly careful with: 

1. Civil service mileage rates 2025  

Employers must apply updated civil service mileage rates for reimbursement calculations, ensuring they are accurate and fairly processed. 

2. Consent and transparency  

Employees need to be informed about how their travel expense data is collected, stored, and used. Consent must be clear, freely given, and specific. 

3. Secure data storage  

From travel records to payroll disbursements, organisations must store all employee travel data securely to prevent breaches. 

4. Access and right to erasure  

Employees can request access to their submitted travel claims or even request deletion of data no longer relevant. 

GDPR principles & process for travel expense payroll compliance 

To ensure compliance when processing travel expenses in payroll, employers should: 

• Ensure fairness and transparency: Make clear how travel expense data is processed and used, and why travel claims require specific data points such as mileage and destinations. 
• Adhere to purpose limitation: Use personal data solely for travel reimbursement and financial compliance, with no unrelated activities. 
• Keep data secure: Implement both technical and organisational measures to protect sensitive information, such as employee-identifiable data collected for each travel claim. 

Example  

An Irish employer reimbursing travel expenses using civil service mileage rates for 2025 should clearly communicate the reimbursement policy to their employees, store data securely within payroll systems, and ensure all related records are up-to-date and compliant with GDPR requirements. 

Strengthening GDPR compliance in 2025  

• Data Subject Rights: HR departments must place emphasis on safeguarding employee data rights, especially for those submitting travel reimbursements within payroll systems. Key rights include: 
• Right of Access: Employees can request to view the details of their travel claims and reclaims. 
• Right to Data Portability: Employees should be able to transfer their travel expense data to another employer or payroll provider in a standard format. 
• Right to Restrict Processing: Staff may request limits in processing travel reimbursement claims if inaccuracies arise. 

Breach notification obligations 

Organisations must alert Ireland’s Data Protection Commission (DPC) of any breach affecting employee financial data, such as travel expense claims, within 72 hours. 

Enforcement and penalties

Non-compliance with GDPR, especially for payroll and travel reimbursement data, can be costly. Penalties include fines of up to €20 million or 4% of annual global revenue, whichever is higher. Since 2018, significant financial penalties have already been levied on companies that mishandle employee and customer data.

Looking ahead

With the dynamic nature of remote work and evolving regulations like the EU Data Act, 2025 demands a proactive approach to compliance. Accurately processing travel expenses using civil service mileage rates and ensuring GDPR compliance in travel-related payroll functions is now a business-critical task for Irish employers. Organisations must regularly audit their systems, train staff, and use technology to maintain best practices.

By treating GDPR as the core of HR and payroll operations, businesses can ensure operational integrity, protect employee rights, and avoid financial and reputational damage.