EU organizations connecting CRM MCP and Ad Platform MCP to Claude or ChatGPT should treat MCP as part of an enlarged processing chain — not a side channel exempt from GDPR.
Processor Mapping
Typical chain: your company (controller for client data) → MCP360 (processor for API orchestration) → ad/CRM platforms (often independent controllers) → AI provider (sub-processor for inference). Maintain Article 28 DPAs with MCP360 and document sub-processors in Annexes.
DPIA Triggers
A DPIA may be required when AI:
Document mitigations: human approval for writes, read-only defaults, retention limits on chat logs per your AI vendor contract.
Minimization in Prompts
Ask for aggregates:
> "ROAS by campaign for DE storefront last 7 days"
instead of exporting customer-level lists into the session. CRM MCP contact tools should be restricted to roles that already had CRM access pre-AI.
Technical Controls
UK and Canada Overlap
UK agencies see UK GDPR AI ad automation. Canadian clients may require PIPEDA considerations.
Reference
Security & Compliance pillar · Model Context Protocol fundamentals