What is a RoPA? GDPR requirements for record of processing activities

  • by Osano Staff
  • · posted on April 18, 2022
  • · 4 min read
What is a RoPA? GDPR requirements for record of processing activities

Laws about data privacy and protection are only as good as the measures taken to enforce compliance. To increase accountability for businesses, GDPR Article 30 introduced new rules regarding how a company maintains records of processing activities (RoPAs).
 
What is a RoPA?
 
Are you familiar with the latest GDPR requirements?
 
How can your organization ensure compliance?
 
We’ll dive into all of these questions in this blog and more.

What is a RoPA?

 
GDPR introduced new terms and rules that set the bar for data privacy worldwide. RoPAs are just one way to ensure a business’s compliance with the Regulation’s standards. According to Article 30, “Each controller and, where applicable, the controller’s representative, shall maintain a record of processing activities under its responsibility.”
 
Think of your RoPA as a snapshot of your data processing practices. It’s a single document that outlines all of your business's data processing activities. Some examples of processing activities include HR, marketing, or third-party activities that process personal data.
 
While keeping records of processing activities is legally required by the GDPR for most businesses, it is also a helpful tool for self-auditing. Maintaining and understanding these records is essential for companies as they seek to identify processing risks. Once you know the risks, you can develop a plan to mitigate them.
 

FAQs about RoPAs: Everything you need to know about GDPR record of processing activities

 
If you’re wondering about RoPA meaning, GDPR answers all your questions. To clear up any confusion, consult Article 30. Record of processing activities guidelines will help you stay in compliance with the authorities and build trust among your clients.

Who needs to maintain a RoPA?

 
All businesses with over 250 employees must keep a record of processing activities. Do you employ less than 250 people? Don’t stop reading yet.
 
You’re still required to maintain a RoPA if:
  • Your processing is likely to result in a risk to the rights and freedoms of data subjects.
  • You process data frequently.
  • You process special categories of personal data, including race, gender, sexuality, religion, and others.
  • You process personal data relating to criminal convictions and offenses.
 
Using these benchmarks, almost every organization is required to keep RoPAs.

What is the best way to format a RoPA?
 
Article 30 of the GDPR requires written records, including those written in electronic form. Electronic records are ideal because they allow businesses to easily add, remove, or amend information. Many companies choose to maintain their RoPAs using Microsoft Excel.
 
Not sure how to format your report? The French supervisory authority, the Commission Nationale Informatique & Libertés, published an example of a RoPA in ODS format.

What information should a RoPA include?

 
The GDPR lays out all requirements for maintaining RoPAs in Article 30. Record of processing activities kept by a data controller should include:
  • Name and contact details of the data controller.
  • The purpose of processing the data.
  • Categories of the data subjects and types of personal data.
  • Categories of data recipients, including those who have already received a user’s data and those who will receive a user’s data in the future.
  • Transfers of data to a third country or an international organization.
  • Time limits for erasure of different categories of data.
  • A general description of technical and organizational security measures.
 
Additionally, data processors must maintain records on behalf of all data processed for the controller. This RoPA should include:
  • Each processor's name and contact details and the name and contact details of each controller that has engaged them to process the data.
  • The categories of processing carried out on behalf of each controller.
  • Transfers of data to a third country or an international organization.
  • A general description of technical and organizational security measures.
 
A RoPA should be easy-to-read and concise. Don’t muddy the report with additional information.

How often should I update the record?
 
To comply with GDPR standards, your organization must keep your RoPAs up-to-date. Any time your procedures for processing information change, you should update your record of processing activities.
 
Your business may find it helpful to appoint a data protection officer (DPO) to spearhead your RoPA procedures. Doing this will protect against duplication of work and accidental omissions.

Who needs to see the record?

 
Article 30 states that all organizations legally required to keep RoPAs should be ready to present the record to supervisory authorities upon request. In case of an audit or in the aftermath of a data breach, supervisory authorities may ask you to submit additional evidence. Additional information may include records of consent, privacy policies, contracts, and other relevant data.
 

Use Data Discovery to keep track of your RoPAs

 
Maintaining a reliable and accurate record of the data you control and process is key to fulfilling the GDPR requirements for RoPAs. Information is spread across dozens or hundreds of systems in most organizations, making data mapping a near-impossible task.
 
Osano’s Data Discovery Platform detects, categorizes, and applies search functionality to your user data across every system. This AI and machine learning-driven platform accurately classifies over 70 types of personally identifiable information (PII) to save time and eliminate human error. Sign up for a demo or free trial today to see how Data Discovery makes compliance easy.

About The Author · Osano Staff

The Osano staff is a diverse team of free thinkers who enjoy working as part of a distributed team with the common goal of working to make a more transparent internet. Occasionally, the team writes under the pen name of our mascot, “Penny, the Privacy Pro.”