Are your recording processing activities accurate, and why does your business need to care about ROPA_

According to Article 30, the company should keep a detailed record of all the activities related to personal data processing, also known as a Record of Processing Activities or ROPA data. 

Companies dealing with an extensive inventory management system will have a harder time complying with the data privacy regulations. 

Let’s understand the risks associated with compliance:

  • First, legal Landscapes are changing every year, so companies who do not systematically monitor data processing can knowingly or unknowingly violate data privacy laws. 
  • The business is full of risks, and improper management can put stakeholders and executive management in the pools of doubts.
  • The employees will fairly not understand the need for implementing effective data management practices across the organization.
  • Full automation is the first step to ensure that the companies fully understand the process of the data processing activity.

If you are wondering whether you fall into the category of compliance with Article 30, then check if you fit into any of the below-described categories:

  • Separate obligations are depending if you are a regulated entity that is a controller or a processor. 

Controller: Any entity that determines the means of processing the personal data

Processor: Entity that processes the personal data on behalf of the Controller.

And the Controller needs to provide a more detailed record than the processor.

  • Organizations with more than 250 employees.
  • The processing activities of the organization should not be irregular.
  • Does not pose any likely risk to the data subjects.
  • Should not include special categories of data. 
  • They should not include the data relating to criminal convictions and offences under Article 10. 
  • Small organizations that fail to monitor their data processing activities and violate Article 30. 

What comprises ROPA records?

  • Names and Contact Information of:
  1. data controller’s representative
  2. data controller 
  3. joint Controller 
  4. data processor
  5. data protection officer
  • Data Subject types
  • Categories of processed personal data 
  • List of receipts who have access to personal data
  • Purpose of personal processing data
  • International Parties who receive the personal data access
  • Organizational security steps that are relevant to each processing activity.

Now the consideration is when does Article 30 apply?

Processing includes any activity or operation performed on personal data. Here are some examples of processing activities of GDPR:

  • Collection,
  • Recording,
  • Organization, 
  • Structuring, 
  • Storage,
  • Adaptation, 
  • Alteration, 
  • Retrieval, 
  • Consultation, 
  • Use, 
  • Disclosure,
  • Dissemination,
  • Alignment,
  • Combination,
  • Restriction,
  • Erasure,
  • Destruction. 

You need to take action with every personal data as per Article 30.

So if you are a large enterprise and want to create individual ROPAs for each line of business, you might want to know how you should create a good ROPA report. 

  • Gain discovery into your data through data discovery. 
  • Collaborate with all data owners within the organization to compile all data processing activities. 
  • Get access to any posing risks and data threats. Figure out any data retention, categories of data, and its shared access within the organization.
  • Use only standard legal templates and provide the people who are accessing the data with proof of compliance. 

An organization under Article 30 needs to use personal and sensitive data more effectively and efficiently. The insights related to the risks and security of personal data can help them align with legal and data privacy requirements. The organization will also be able to implement effective data management practices. 


Originally posted 2021-08-26 15:11:17.