GDPR’s Article 30: Creating & Managing your Record of Processing Activities (ROPA)

Gal Ringel
Gal Ringel
Feb 23, 2022
min read
GDPR’s Article 30: Creating & Managing your Record of Processing Activities (ROPA)

ROPA gives users and authorities a practical way to influence data processing and protection-related rights. Let’s dive into the details to understand what this means as a business and how to meet the required ROPA standards.

The GDPR brought many new terms into our lives, including the Record of Processing Activities (ROPA). The legal requirement appears in Article 30 of the law, stating that companies must keep a detailed record of relevant data-related activities and policies to enable a long list of online privacy demands and audits. 

Getting to know Article 30

GDPR’s Article 30 refers to any data collection or usage involving personal information. It states that the record of such steps must be kept in written or electronic form, covering specific information:

  • Identification of the controller and its representatives: The company should identify those responsible for collecting and processing personal data. If the company has a Data Protection Officer, their details will also be included in the record. This information offers the immediate address that authorities can approach with queries. But it also provides another benefit; by listing and naming the people in charge of data processing, the law places responsibility on the shoulders of the company executives, making it clear that their task is not to be underestimated. 
  • The purpose of data processing: The GDPR demands that companies only keep and use data for specific and clear purposes after gaining users’ consent. Listing the purpose here enables authorities to keep track of any contradictions between the intended use and the actual one, as well as the completion of any process that demands the removal of data. 
  • The type of data collected and processed: Companies should keep track of all processed data categories to understand why it’s considered personal and treat the data appropriately while serving the relevant purpose.
  • Additional parties with access to data: Whenever personal data is shared with in-house stakeholders or 3rd parties, a record of the shared data and those who gained access must be kept under ROPA. For a good reason, considering that any subject request for a personal data report or deletion includes deletion from 3rd parties with access to the users’ data. It is impossible to ensure that the data is successfully removed or collected from all relevant sources when requested without keeping track of the company's data-based connections.  
  • Time limits: We’ve mentioned the connection between the purpose the personal data serves and the time to deletion. This category of recorded information details the time limit specifically, helping companies and auditors reach an easy conclusion. 
  • Security measures: Companies’ ROPA should detail which technical and organizational measures are taken to protect personal data from breaches and unauthorized access. A general description is typically sufficient. 

When Does ROPA Apply? 

The GDPR specifies that ROPA requirements apply to companies of 250 employees or more, or if one of the following criteria takes place:

  • The processed information puts users’ data privacy rights at risk.
  • Data processing is done regularly rather than occasionally.
  • The data involves specific categories such as political opinions, union membership, religious beliefs, and more.  

<hl>The fact that many organizations rely on data as part of their ongoing work and do not process it occasionally makes Article 30 and ROPA requirements relevant to the vast majority of companies. When GDPR applies, ROPA is likely to apply, too.<hl>

Tips for Building a Proper ROPA Process

  • Working with legal experts who understand GDPR requirements is essential when building your ROPA process. This will ensure that the latest law demands are fulfilled, and any upcoming updates are considered.
  • Your record should cover a long list of documents, such as processing activities, verification documents, records of consent, communication with third parties, relevant contracts, privacy notices and changes, security measures and updates, data breaches, and more.
  • Creating a structured ROPA categorized by data type helps tackle this task, which may seem overwhelming at first. Ensuring that all relevant guidelines include instructions regarding ROPA documentation is also critical. Prepare templates for representatives to fill during each relevant data-related process. 
  • All relevant ROPA information and documents should be linked, and all relevant stakeholders mentioned by name to make it easier to answer any questions if an audit involving your ROPA takes place. Train managers to understand ROPA guidelines and ensure that IT professionals have a deep grasp of access control. 
  • Be your own auditor, and don’t wait for an actual audit to learn which parts are missing from your ROPA puzzle. Review your policies and check to ensure that your documents and team are fully prepared. Ask the hard questions regarding your company’s data practices to find any contradictions or gaps that demand your attention. 

The Most Important Tip of All: Data Mapping Makes ROPA Requirements Easier to Follow

This is perhaps the most crucial piece of advice. Maintaining an organized data structure at all times and regardless of specific ROPA demands is vital. <hl>An accurate, trustworthy data pool makes it easier for companies to answer any question or request related to data, saving hours of research, potential compliance risks, and a lot of frustrations all around.<hl> When companies have a solid data mapping strategy and technology in place, things like ROPA reports or responding to data subject requests becomes just another easy task to handle instead of a paralyzing burden. 

This also provides valuable insights regarding your general data conduct, which should help you treat customers’ information better and discover helpful details that fell between the cracks. You’ll be able to find data duplicates and redundancies, streamline your processing flow, and more.  

<hl>Reduce compliance and security risks by moving on from spreadsheets and interviewing your heads of departments by using a live and automated data mapping solution.<hl> Mine’s automated no-code Data Mapping tool includes real-time data mapping capabilities for GDPR compliance and ROPA reporting and reveals up to 100% of all data sources. 

The new era of data ownership asks that companies take their data privacy seriously at all times, and your approach to data mapping can determine whether your organization manages to do so. ROPA may be the first reason you take a closer look at your data processing habits, but it doesn’t stop there. Implementing a sophisticated and easy-to-use live-data mapping technology will allow companies to gain deep insights to reduce privacy risks, increase security, and facilitate their privacy requests much faster.