Using Real Customer Data for Testing: Best Practices and Legal Considerations

Using Real Customer Data for Testing: Best Practices and Legal Considerations

3 July 2024 Stephan Petzl Leave a comment QA

When it comes to software testing, one of the most debated topics is the use of real customer data. This article will explore the common practices, policies, and legal considerations surrounding this issue, offering practical guidance for your testing processes.

Is It Common to Use Real Customer Data for Testing?

In general, it is not common to use real customer data for testing due to privacy, business, and legal concerns. However, there are instances where it might be necessary to use real data, especially in complex systems where certain issues cannot be reproduced with test data alone.

One of the most significant legal considerations is the General Data Protection Regulation (GDPR) in Europe, which strictly regulates the use of personal data. According to GDPR, personal data must be anonymized in such a way that the data subject is no longer identifiable. Anonymized data can be used without consent, but it is crucial to ensure that the anonymization process is irreversible.

Other industry-specific regulations, such as the Payment Card Industry Data Security Standard (PCI DSS), explicitly prohibit the use of actual customer data for testing. Additionally, the US government has developed draft guidelines on this topic, which can serve as a good starting point for understanding the legal landscape.

Best Practices for Using Real Data in Testing

  • Anonymize Data: Ensure that all personal data is anonymized to comply with GDPR and other relevant regulations.
  • Obtain Consent: If anonymization is not possible, obtain explicit consent from the data subjects before using their data for testing.
  • Use Test Data: Whenever possible, use dedicated test data that mimics real data without containing any sensitive information.
  • Implement Security Measures: Ensure that robust security measures are in place to protect any real data used in testing environments.
  • Review Industry-Specific Regulations: Be aware of and comply with any industry-specific regulations that may apply to your testing processes.

Practical Examples

In some industries, it is challenging to test without customer data. For example, in software that uses social security numbers for lookups, anonymization must ensure that the same result is produced across multiple tables while retaining the standard format.

Another example is in systems where data syncs between multiple systems. If your application is not the system of record, anonymizing data without losing the ability to sync to the master system can be difficult.

Scalability issues may also arise when the test database size is significantly smaller than the customer’s data set. In such cases, using a copy of the production database may be necessary to reproduce and fix the problem.


Using real customer data for testing is a complex issue that requires careful consideration of legal, privacy, and business implications. By following best practices such as anonymizing data, obtaining consent, and using dedicated test data, you can mitigate risks and ensure compliance with relevant regulations.

For those looking to streamline their testing processes, consider using tools like Repeato. Repeato is a no-code test automation tool for iOS and Android, which allows you to create, run, and maintain automated tests quickly and efficiently. With its computer vision and AI capabilities, Repeato ensures that your testing is both thorough and compliant with industry standards.

For more information on Repeato and how it can enhance your testing processes, visit our documentation page.

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