TL;DR: Quick Reference
What: Architectural blueprint for deploying HubSpot with full GDPR compliance across EU and US operations
Key Benefit: Avoid costly rework and regulatory penalties with a properly structured multi-region HubSpot deployment
For: Financial services firms, asset managers, and banks operating in both European and US markets
Bottom Line: Run separate EU/US instances with controlled data flows and proper consent management to achieve genuine GDPR compliance
Author: Vantage Point | Category: HubSpot, GDPR, Financial Services, Architecture
GDPR compliance on HubSpot is not achieved by toggling on the data privacy settings and moving on. For financial services organizations — particularly those operating across the EU and US — compliance requires a deliberate architectural approach that addresses data separation, consent management, cross-border transfer controls, and audit readiness from the foundation up.
At Vantage Point, we've implemented these architectures for financial services clients that operate in both markets, including institutional asset managers and high-frequency trading firms with European subsidiaries. The lesson we've learned is that getting the architecture right at the start prevents expensive rework later.
The most common and compliance-friendly approach is to run separate HubSpot instances for European and US operations. Each instance operates with its own data center assignment — the EU instance hosted in Frankfurt, the US instance in the eastern United States. This ensures that European customer data resides in the EU by default and that US data processing does not intermingle with EU-regulated data.
From a contractual perspective, many firms also execute separate agreements for each instance. This provides a clean paper trail demonstrating that the European business engaged HubSpot independently, with its own Data Processing Agreement governing EU data processing obligations.
Separate instances do not mean completely siloed operations. Financial services firms typically need some degree of data sharing between regions — for example, global reporting, shared product information, or coordinated marketing campaigns. The key is controlling what data flows between instances and ensuring that any cross-border transfer is governed by appropriate legal mechanisms.
In practice, integration between separate HubSpot instances is usually handled through middleware or custom API-based synchronization that transfers only the data elements necessary for business operations. Contact-level personal data stays in the region where it belongs. Aggregated reporting data, product catalogs, and non-personal operational data can flow more freely. Every data flow should be documented in a Record of Processing Activities (ROPA) that your DPO can reference during audits or in response to supervisory authority inquiries.
For EU-hosted accounts, HubSpot enables data privacy settings by default. These include cookie consent banner functionality, lawful basis tracking for communications, consent management through forms and subscription preferences, GDPR-compliant permanent deletion capabilities for honoring data subject requests, and automatic unsubscribe link insertion in marketing emails.
HubSpot also supports the operational side of data subject access requests (DSARs). When a contact exercises their right to access, rectification, or erasure, HubSpot's tools allow you to locate all data associated with that individual, export it, modify it, or permanently delete it across the platform. The permanent deletion is irreversible and removes data at the record level, which is exactly what GDPR's "right to be forgotten" requires.
Financial services firms must be particularly rigorous about consent because they often communicate with clients across multiple channels — marketing emails, transactional communications, regulatory notices, and advisory communications — each of which may have different legal bases under GDPR. HubSpot's subscription types allow you to create distinct communication categories, each with its own consent tracking.
The critical point is configuring this correctly at implementation. A wealth management firm, for example, might need separate subscription types for marketing communications (requiring explicit consent), client service communications (legitimate interest), regulatory notices (legal obligation), and event invitations (consent). Each type should track its own lawful basis, and your consent collection forms should clearly distinguish between them so that a client's opt-out of marketing materials does not inadvertently suppress a required regulatory communication.
Before going live with HubSpot in a financial services context, you should confirm the following elements are in place. Your data center assignment should be verified as EU for European operations. Data privacy settings should be enabled with lawful basis tracking active for all communication types. Cookie consent banners should be configured for all HubSpot-hosted pages, with settings that comply with the ePrivacy Directive requirements applicable in your jurisdiction. Your subscription types should reflect your actual communication categories with appropriate legal bases documented for each.
Beyond the platform configuration, you need documented processes for handling DSARs within the GDPR's one-month response window, a data retention policy that defines how long different categories of data are stored and when they are purged, a documented process for managing subprocessor changes (including subscribing to HubSpot's subprocessor update notifications), and a breach notification procedure that aligns with GDPR's 72-hour reporting requirement. Your DPO should sign off on the entire configuration before production data enters the system.
GDPR compliance is not a one-time project. HubSpot evolves its features and subprocessor relationships over time, and your own business processes will change as well. Establish a quarterly review cadence where your compliance team revisits the HubSpot configuration, reviews any subprocessor changes, audits user permissions, and verifies that consent records remain intact and accurate.
At Vantage Point, we support financial services clients on an ongoing basis through managed services retainers that include compliance configuration reviews as a standard component. Because we specialize in financial services, we stay current with both platform changes and regulatory developments, ensuring that your HubSpot deployment remains aligned with evolving GDPR interpretations and enforcement trends.
About Vantage Point: Vantage Point is a boutique consulting firm exclusively serving financial services organizations. With deep expertise in both HubSpot and the regulatory landscape governing financial services in the US and Europe, we help firms implement and maintain compliant CRM architectures. Learn more at vantagepoint.io.