Grammarly GDPR and SOC 2 compliance: what happens to your text
Grammarly is installed in browsers, desktop apps, and productivity tools used by millions of employees. It works by reading and analyzing text as employees type, which means it processes a significant amount of potentially sensitive content: customer emails, support responses, internal Slack messages, code comments, and more.

Most compliance reviews miss Grammarly because it looks like a spelling checker. It is not. It is a cloud-based text processing service that sends content to Grammarly's servers for analysis.
What Grammarly actually sends to its servers
When Grammarly is active, the text you type in browser-based applications, email clients, and other supported interfaces is sent to Grammarly's servers for grammar and writing analysis. This happens in near real-time as you type.
For employees using Grammarly in:
- Gmail or Outlook Web → Email content, including customer emails
- Zendesk, Intercom, or other support tools → Support ticket content, which may include customer personal data
- Notion, Confluence, or other wikis → Internal document content
- Slack via the browser → Message content
- Any other web application → Whatever text is typed in that application
The scope of data exposure depends on where employees have the Grammarly extension installed and active.
GDPR requirements
Plan tier matters
| Tier | DPA | Training opt-out | Appropriate for work data |
|---|---|---|---|
| Free | No | No | No |
| Premium (personal) | No | No | No |
| Business | Yes | Yes (configurable) | Yes |
| Enterprise | Yes | Yes | Yes |
The compliance threshold is Grammarly Business. Free and Premium plans do not include a DPA and use consumer terms that permit use of content for product improvement. This is a common gap: employees sign up for Grammarly Free or Personal Premium and use it with company accounts.
The shadow Grammarly problem
Many organizations have employees using personal Grammarly accounts on company devices, often installed before they joined the company. These personal accounts are not covered by the company's Grammarly Business DPA. The text processed by these personal accounts, including potentially sensitive work content, is processed under consumer terms.
Remediation: audit Grammarly installations on managed devices via your MDM, deploy the Grammarly Business extension centrally, and communicate to employees that personal Grammarly accounts should not be used on company devices.
Training data configuration
For Grammarly Business, administrators can configure whether employee text is used to improve Grammarly's AI. Review your admin settings at account.grammarly.com/admin and verify the AI improvement setting aligns with your policy.
Subprocessors
Grammarly uses third-party infrastructure providers (cloud hosting) to process text. Grammarly's DPA includes provisions for subprocessor use and Standard Contractual Clauses for transfers of EU personal data. Review Grammarly's current subprocessor list for specific providers.
SOC 2 requirements
Vendor inventory (CC9.1)
Add Grammarly Business to your vendor inventory:
- Service scope: AI-powered writing assistant; processes typed text across browser applications
- Data processed: Employee-typed content in web applications, email, documents, support tools, may include customer personal data
- Risk tier: High if customer support agents or sales teams use Grammarly; Medium if limited to internal documentation
- DPA status: Grammarly Business DPA in effect
- Security documentation: Grammarly publishes security information and compliance documentation via trust.grammarly.com
- AI training opt-out: Configured per your policy
Access controls (CC6)
- Are Grammarly installations managed centrally (MDM) or employee-installed?
- Do departing employees have their Grammarly Business accounts deprovisioned?
- Are employees blocked from using personal Grammarly accounts on managed devices?
- Is Grammarly enabled in high-sensitivity applications (e.g., is it active in your HRIS or financial systems)?
Acceptable use policy (CC1)
Your policy should address:
- Which Grammarly account type employees must use (Business accounts only)
- Whether employees may install personal Grammarly accounts on company devices
- Which applications are approved for Grammarly use (and which should have it disabled)
- Specific guidance for customer-facing employees about Grammarly and customer data
Reducing Grammarly's data access
Tip
If you want to allow Grammarly while limiting data exposure:
- Use the Grammarly Business desktop app rather than the browser extension, it has more targeted access than a browser extension that reads all web content
- Disable Grammarly in sensitive applications: browser extensions can be configured to not run on specific sites
- Deploy via MDM with a configuration that limits the sites where Grammarly is active
- Review and approve the Grammarly Business application allowlist in your MDM to ensure only managed accounts are in use
Getting Grammarly audit-ready comes down to mapping its data flows to your SOC 2 and GDPR controls, confirming the DPA and sub-processors, and keeping that evidence current as the service changes. If you would rather a security leader owned that work than track it in a spreadsheet, book a call.
Related reading
- AI tools and GDPR/SOC 2: the complete guide
- Microsoft Copilot GDPR and SOC 2 compliance
- SOC 2 vendor management: how to satisfy CC9.1
- SOC 2 for engineering teams
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