Article 4 (6) of the GDPR sets the definition for a ‘filing system’. If the personal data that the company processes manually is in structured form and the processing is conducted in a database, then yes GDPR does apply. If the processing is one-off and the company does not use a database, then GDPR might not apply.

What is a Data Processing Agreement (DPA) Playbook
Data Protection Agreement What is a Data Processing Agreement (DPA)? A DPA is a contract between a controller and a processor that explains what personal