1. If an organisation collects, stores or processes information on EU nationals, GDPR applies. It doesn’t matter where the organisation itself is based. Santa’ workshop may be based in Canada, northern Finland or Russia, but it doesn’t matter. Santa’s list involves quite a few EU citizens.

GDPR applies to Santa.

2. Is the data ‘personal’? Well, this is pretty obvious – Santa provides perhaps the most tailored gift-giving service in the world (sorry Mr. Bezos…) so if he’s not working off a list that holds personal data then water is clearly not wet.

Santa works with personal data of EU citizens.

3. If an organisation holds personal information on an EU citizen, that person is able to ask the organisation what information is held on them and the organisation must comply with the request. Now, seriously, has anyone among us, at any point, sent a letter to Santa’s workshop and actually gotten a reply? No, thought not…this is strike 1 for Santa.
4. Related to point 3, the person should also be able to request that the personal data held on them by the company is deleted. I’m not sure why anyone would want to do this, but nevertheless, Santa’s Workshop Inc. isn’t known for its customer support channel and accordingly Santa is unable to comply with any delete request. Strike 2.

That’s it – Santa is clearly not GDPR compliant.