Why Small Display Signature Pads Risk GDPR Non-Compliance

When it comes to collecting legally valid signatures on contracts, informed consents, or privacy notices, the device used is far more than a convenience tool. It is an essential component in ensuring compliance with the General Data Protection Regulation (GDPR) and other European legal frameworks.

Many organisations still rely on graphometric tablets with LCD screens of only 5 inches. While compact and inexpensive, these devices present serious risks of non-compliance and may undermine the validity of the consent obtained.

The Problem with Small Displays

Limited Readability - Violation of Transparency (Art. 12 GDPR)

A 5-inch display does not allow the full document to be read clearly. The signer may only see a fragment or have to scroll excessively. This restricts transparency and clarity, violating Article 12 GDPR, which requires that information provided to the data subject be “concise, transparent, intelligible and easily accessible.”

Uninformed Consent - Violation of Valid Consent (Art. 7 GDPR)

Consent is only valid if it is informed, specific and unequivocal. If the signer cannot review the entire text of the contract or consent form before signing, the consent risks being invalid under Article 7 GDPR. In practice, a signature collected on a small screen may be legally challenged because the signer could not reasonably have understood what they were agreeing to.

Accessibility Concerns - European Accessibility Act (EAA)

The European Accessibility Act (Directive (EU) 2019/882) requires digital products and services to be accessible to all users, including the elderly and people with disabilities. A small screen creates barriers to legibility, zooming, and navigation, potentially excluding certain categories of users and opening organisations to accessibility non-compliance.

Recommended Best Practice: Use Large Format Devices

To ensure legal certainty, signature devices should have a display of at least 10.1 inches. Larger screens allow:

• Full visibility of documents without scrolling.
• Clearer fonts and layouts, enhancing accessibility.
• Better user experience, fostering confidence and legal strength in the consent process.

EnSign11: Compliance and User Experience by Design

Euronovate developed the EnSign11 signature pad precisely to address these compliance and usability concerns.

With its 10.1-inch high-resolution display, EnSign11 guarantees:

• Optimal readability: the entire document is visible in one view.
• Valid informed consent: users can review and understand before signing, supporting GDPR Articles 7 and 12.
• Accessibility compliance: designed with the European Accessibility Act in mind, ensuring inclusivity for all signers.
• Advanced security: combined with EnSoft biometric software, EnSign11 captures pressure, speed, and movement data, delivering Advanced Electronic Signatures (FEA) compliant with eIDAS.

By choosing EnSign11, organisations not only meet strict legal and regulatory requirements, but also demonstrate a commitment to customer trust, inclusivity, and sustainable digital transformation.