Customer files are useful resources for businesses. They contain all of the information the business knows about a customer, including their legal name and contact information. Customer files are the foundation of all business relationships because every invoice and reminder the business sends and every payment the customer makes come from information in the file.

An error in a customer record can have serious consequences for a business. From a financial perspective, an invoice sent to the wrong contact, a missing detail, or an expired payment authorization can delay payment by several weeks. From a legal perspective, an incomplete record can result in noncompliant invoices, which are subject to heavy penalties. In addition, a record containing inaccurate data or retained beyond the necessary period can constitute a violation of the General Data Protection Regulation (GDPR).

In this article, we explain what businesses need to know about customer files in France, including their contents, benefits, legal obligations, and tips for creating and managing them.

Key takeaways

• Customer files centralize useful information about customers. This includes their names, contact information, billing, payments, relationship histories, and compliance. Customer files are resources used by sales, accounting, and customer service departments.
  
• Well-managed customer files help ensure accurate invoices, speed up payment times, minimize nonpayments, and facilitate tracking of business relationships (e.g., subscriptions, renewals, reminders).
  
• Customer files containing personal data are subject to the General Data Protection Regulation (GDPR). As such, businesses must be able to demonstrate purpose, legal basis, provision of information to data subjects, storage periods, access restrictions, and records of processing activities.
  
• Data must be collected at the right time, verified against reliable sources, structured in a single software system, and updated regularly to avoid errors, duplications, and obsolete information.
  

What is a customer file?

A customer file is a centralized place that stores all useful information about a customer. This includes the customer’s name, contact information, tax references, payment terms, payment methods, and purchase history. Customer files are a shared resource used by a business’s sales, accounting, and customer service departments.

For subscription-based businesses, customer files are more than just advanced versions of address books. They contain information that triggers payment collections, including Single Euro Payments Area (SEPA) transfer mandates, due dates, subscription packages, and renewal dates.

What is the difference between a customer file and a clientele file?

A customer file contains information about a single customer. A clientele file contains multiple customer files. The first is a resource that employees use in their everyday work. The second is a business asset that adds value if the business is sold. The National Commission for Information Technology and Civil Liberties (Commission nationale de l’informatique et des libertés, or CNIL) also reviews clientele files during audits.

What information do customer files need to contain?

Customer files typically include several information blocks. These include the customer’s name, contact and billing information, payment information, relationship history, and compliance information. When the customer is a business (i.e., B2B), the record must contain information required to create compliant invoices, including the customer’s business name, address, and Business Directory Identification System (SIREN) number.

Here are the six main information blocks required in a business customer’s file.

Legal name

Customer files need to include the customer’s exact legal name, their legal form, SIREN or establishment directory identification system (SIRET) number, French Classification of Economic Activities (NAF) code, and intracommunity value-added tax (VAT) number, if applicable.

Contact information

Businesses can also include the customer’s registered office address, billing address (if different), and shipping address. They also need to include the customer’s business and accounting contact persons.

Billing information

Customer files can contain payment terms, applicable VAT rates, and email addresses for invoices, which can be found in the directory at the SIREN or SIRET level.

Payment information

Subscription-based businesses need to store the customer’s SEPA unique mandate reference (UMR), date of signature, date of last payment, and subscription status. Payment methods with an expiration date (e.g., bank cards) need to include that date.

Relationship history

Businesses can record the date of first contact, quotes, purchase histories, invoices and their statuses, payment incidents, and claims processed.

Compliance information

Customer files need to include the legal basis for processing personal data, sources of the data, consent for marketing (if required), and date of last contact. This last item is useful for determining how long to keep prospects’ data.

Note: When the customer is an individual (i.e., B2C), the content of the customer record remains largely the same but with two changes. The last name, first name, and addresses required for billing or delivery replace business identifiers, such as VAT numbers. Marketing via email or text message generally requires prior consent, with an exception for existing customers who are contacted about similar products or services offered by the same company. Customers must be able to opt out easily.

Sample customer file

Below is a sample customer file for Studio Lumen SAS, a fictional company that subscribes to a monthly plan and is billed via SEPA transfer.

Click here to download a sample customer file to use as a template.

Why do businesses need to create customer files?

Creating customer files helps businesses collect payments faster, minimize nonpayments, grow revenue generated by each customer, and save time. The information is centralized in a structured database and becomes a resource that sales, accounting, and legal departments can all use. Here are some of the benefits of creating customer files:

• Collect payments faster and minimize nonpayments
  Valid mandates, accounting contacts, and payment histories can help ensure that businesses send payment reminders to the right people. This can make the collections process more efficient.
  
• Ensure invoice compliance for faster processing
  Mandatory information—including the customer’s SIREN, which is required for electronic invoicing—can be populated directly from the customer file. This helps avoid repeated corrections and noncompliant invoices.
  
• Retain customers and increase customer lifetime value
  Up-to-date customer files show which accounts make up the largest part of recurring revenue and which are spending less than before. Businesses can then offer higher-level packages at renewal time and reengage at-risk accounts before they cancel.
  
• Help employees save time
  Sales, accounting, and customer service teams can share a single resource instead of having to check with each other and collate information from multiple sources. This can speed up processing times and prevent conflicting responses from different departments.
  
• Create a transferable, lasting asset
  Customer files—where the processing of personal data is based on identified legal grounds with documented sources and retention periods—retain their value when the business is sold. Then, the buyer can verify that the data can be legally used.
  

What legal obligations apply to customer files?

Customer files that contain data on individuals constitute personal data processing and are subject to the GDPR. Businesses must specify the purpose and legal basis of customer files, inform data subjects, collect only necessary data, determine appropriate storage periods, restrict access to files, and record processing activities.

Legal basis

The legal basis depends on how the data is used. Processing an order or providing after-sales service is based on the performance of the contract, while retaining invoices fulfills a legal and accounting obligation.

Email and text message marketing follows special rules set forth in Article L34-5 of the Postal and Electronic Communications Code. For B2C transactions, this legal basis requires the customer’s consent. For B2B transactions, businesses can market without prior consent. This is the case when the message is related to the recipient’s business; the recipient is informed of the marketing; and the recipient can opt out. Businesses can market to existing customers without their consent when offering similar products and services. With each message, customers must have the option to opt out.

Storage periods

Customer information required to conduct the business relationship can be stored for the duration of the relationship. Information used for marketing purposes can be stored for three years from the end of the business relationship.

Some information can be stored in an intermediary archive if justified by legal or documentation obligations. Under Article L123-22 of the Commercial Code, accounting documents—including invoices—must be kept for 10 years.

Records of processing activities

The record of processing activities is the company’s internal inventory of all data processing operations—from the customer database to payroll. For each processing operation, it specifies the purpose, data involved, recipients, and retention period.

Customer files are processed regularly and continually, so they must be included in the record, regardless of the business’s size. The CNIL offers a simplified template for very small enterprises (VSEs) and small and medium-sized enterprises (SMEs). Article 30 of the GDPR exempts businesses with fewer than 250 employees, but this exemption applies only if the processing is occasional, poses no risk, and does not involve sensitive data.

Violations of basic GDPR principles (e.g., storage periods) are punishable by fines of up to €20 million or 4% of annual global revenue. Failure to maintain processing records is punishable by smaller fines of up to €10 million or 2%.

How to create a customer file

Creating a customer file involves several steps. These include determining fields that will be useful to the business, choosing software to house the database, collecting information at specific times (e.g., when quotes are signed), and verifying legal information against official sources before issuing the first invoice.

Here are the steps to creating a customer file.

Decide on necessary fields

The documents that the business issues based on the customer file dictate which fields are necessary. These can include SIREN numbers and addresses for invoices, bank references for SEPA mandates, or the negotiated terms for contracts.

Determine data sources

Businesses need to verify the sources of customer information. This involves corroborating customer-provided information with documentation, periodically re-verifying data from public registers, and ensuring that information calculated by software—such as due dates and balances owed—updates automatically. Identifying the source of each field’s information helps businesses determine how to ensure the information is accurate and how often to verify it.

Collect information at specific times

Typically, signed quotes and purchase orders are the most efficient data collection points because customers are agreeing to provide their legal identifiers and banking information. Sometimes, information is provided earlier, such as on website registration forms, online appointment programs, demonstration requests, or trade shows.

Verify legal data at the source

Check business names and SIREN numbers in the French government’s business directory, and verify intracommunity VAT numbers in the European Commission’s VAT Information Exchange System (VIES) database.

Choose software and restrict access

Spreadsheets are feasible for businesses with no more than a few dozen customer accounts. For businesses with more customers, customer relationship management (CRM) software or software for recurring billing—such as Stripe Billing—helps prevent duplicate entries, stores modification histories, and prevents unauthorized users from viewing banking information.

Inform customers at the time of collection

When businesses collect personal data, they must include information notices on their documents (e.g., forms, invoices, quotes, contracts). Notices need to name the data controller and state the purpose and legal basis for processing. They also need to include the data storage period, data recipients, and data subject’s rights and explain how the subject can exercise their rights.

Standardize formats and test a full cycle

Customer files need to use a single format for dates and numbers. Important fields need to be configured as mandatory to minimize data entry errors. Before releasing the template, use a test customer file to issue a complete invoice. Verify that all fields populate automatically from the test file without manual data re-entry.

How to manage customer files

To manage customer files correctly, businesses must designate a data controller, update files at each event (e.g., contract signing, contract amendment, failed payment), and link files to billing software to prevent duplications. Businesses need to purge customer files periodically to delete or anonymize files kept beyond the storage period.

Here is a closer look at how to manage customer files:

• Designate a data controller
  A designated employee manages information fields, approves corrections, and oversees the quality of customer files. Without a data controller, errors can compound undetected, and data can become inaccurate within a few months.
  
• Link customer files to billing software
  Entering customer information multiple times (e.g., in CRM and billing software) increases the risk of error. Linking customer files to a single tool via native synchronization or an application programming interface (API) connection allows invoices, mandates, and reminders to populate automatically without manual data re-entry.
  
• Trigger updates after events
  Data controllers must update fields and indicate modification dates after events, such as contract signatures, changes in contact persons, declined payments, or contract terminations. Updates need to appear automatically on invoices, mandates, and reminders sent by the billing software.
  
• Purge files annually and track duplicates
  Inactive customer file accounts retained beyond the storage period need to be deleted or anonymized yearly. Businesses also need to perform SIREN number uniqueness checks to prevent duplicate files. Finally, keeping logs of data viewings and exports helps track who is downloading customer files and indicates unusual or massive data exports.
  

How Stripe Billing can help

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FAQs about customer files in France