[FAQ]

Hi,

I’m based in Germany and I run a channel for my small consulting business. I’ve been reading up on GDPR, and to be honest, I’m now a bit paranoid about my responsibilities as a channel owner.

What data am I actually responsible for? I’m not collecting anything weird, but I do run polls and I have a linked discussion group. If I run a contest and ask for someone’s email address via a bot to send them a prize, am I suddenly a ‘data controller’? What about the user list itself?

I just want to make sure I’m not accidentally breaking any serious privacy laws. Any other EU-based admins who have a clear policy for this?

[Jeff Bullas]

This is one of the most important and least understood responsibilities of running a professional channel.

Short Answer: The moment you use any content format to actively collect personal data—like an email address—you become a data controller and are responsible for GDPR compliance, regardless of Telegram’s own policies.

Let’s break down how different content formats create different levels of legal responsibility.

Your responsibility shifts from ‘publisher’ to ‘data controller’ based on your actions. Firstly, when you are only posting standard broadcast content, such as text posts, images, or video files, your liability is minimal. You are simply publishing content, and you have no access to your members’ private data. Secondly, your risk level changes when you use interactive formats like text-based polls. While anonymous polls are safe, a poll that collects user-identifiable responses could be seen as processing personal data, though the risk is still relatively low. Thirdly, you cross a critical legal line the moment you use a tool, like a bot, to explicitly ask for and store personal information. This includes using a text-based bot to collect email addresses for a contest or a document for a sign-up sheet. At this point, you are actively collecting and storing data. This means you are solely responsible for getting explicit consent, stating how you will use that text-based data, how you will store it securely, and how a user can have it deleted, all of which are core requirements of GDPR.

Cheers,

Jeff

[Author]

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