Records of Processing Activities Examples (Best Examples)
Understanding and maintaining accurate Records of Processing Activities (RoPA) is an essential part of complying with GDPR regulations.
In this article, we’ll explain what a RoPA is, why you should create one, and what it includes, and we’ll also give you some Records of Processing Activities examples from different industries to better understand this important document.
Let’s dive right in.
- A RoPA is a document or record that outlines the data-processing activities of an organization
- RoPA is mandatory for companies with 250 or more employees
- At a minimum, a RoPA includes the name and contact details of the data controller and DPO, the purpose of processing, data subject categories, who has access to the data, and the lawful basis for processing
Understanding What a Record of Processing Activities is
A Record of Processing Activities (RoPA) is a review of the data processing activities a business executes.
A RoPA is required for any business that has at least 250 employees or more. If a company has fewer than 250 employees, it is still under obligation to create a RoPA if:
- It regularly processes data and not occasionally
- Its data processing activities may be a risk to the data subject’s rights and freedoms
- Its data processing activities include sensitive personal information (SPI) or criminal conviction data.
This document doesn’t need to be overly in-depth, but it should answer the following questions:
- How is your business processing data?
- What data are you processing?
- Why are you processing data?
- Where are you processing this data?
- Who are you disclosing the data to?
Why Should You Create a RoPA?
Through the RoPA, your business demonstrates its compliance with the supervisory authority.
In particular, businesses can demonstrate that they can implement the principle of accountability of the GDPR and that they understand the implications of processing personal data.
It’s important to note that a RoPA is not the same as a Data Privacy Assessment (DPIA) and that this is a standalone document. This means that the supervisory authority should not be expected to review several documents for a RoPA.
What Information Should be Included in a RoPA?
Article 30 and Article 6 of the GDPR outline what information is mandatory to include in a RoPA. This information has to be in writing or electronic form and must be made available at the request of the supervisory authority.
The information that a data controller and processor must include in a RoPA are:
- Name and contact details of the controller, processor, and the data protection officer
- Data subjects that the processed data relates to
- Purpose of data processing
- Categories of data processed
- Information regarding data transfers outside the EU and EEA
- Time limits for deletion
- Data security measures (see Article 32(1))
- Legal basis for data processing (see Article 6 of GDPR)
In addition, the business can include the following information, though this is not mandatory by the GDPR:
- What IT systems were used to process this data
- Use of data processors
- Are there special categories (SPI)
- A further description of the data processing
- Any works council agreements that regulate data processing
Legally Required Minimum RoPA Example
The legally required minimum of information that a RoPA should include and needs to be made available to the supervisory authority per its request is again outlined in Article 30 of the GDPR.
Here is a minimum required Records of Processing Activities example:
- Name and contact details of the data controller: Company, address, postal code, phone number, email address
- Name and contact details of the DPO: Outsourced DPO company, email
- Purposes of processing data: i.e., payroll administration, promotional emails, etc.
- Description of the data subjects categories: For example, permanent company staff
- Who the data have or will be disclosed to: For instance, bank, legal advisor, etc.
- Categories of recipients in other countries or organizations that the data is or will be disclosed to
- The name of the country/international organization
- Lawful basis: For example, Article 6(1)(b)
Records of Processing Activities Example for Different Industries
Next, we’ll show two Records of Processing Activities examples for different industries, financial services, and healthcare.
RoPA Example 1: Financial Service Company
RoPA Example 2: Healthcare Service Company
Importance of Updating a RoPA
As you can see from these two Records of Processing Activities examples, the information in RoPA is often subject to change. This means that a RoPA is a “living” document and needs to be kept up-to-date.
- Regularly reviewing and updating the RoPA document
- Keeping the RoPA in an electronic form rather than paper (as it is easier to update and save)
- Removing the processing activities that are no longer taking place from the RoPA
- Educating employees on the importance of adding new products or services that require processing to the RoPA
Understanding and maintaining a Records of Processing Activities (RoPA) is vital for companies to comply with GDPR regulations.
This crucial document oversees the data-processing activities within your organization - from collecting personal client information to processing it. It helps identify vulnerabilities that, if not managed properly, could lead to legal problems.
What else do you need to demonstrate your GDPR compliance? Find out by contacting our compliance and data privacy experts at Captain Compliance, and we’ll make sure you have everything covered!
What are the Records of Processing Activities for GDPR?
A Record of Processing Activities (RoPA) is a document that shows the data processing activities of the company along with other relevant information.
This document serves to showcase the company’s accountability and commitment to uphold the best practices when it comes to data processing activities.
What are Examples of Processing Activities?
Data processing activities include everything from gathering data, storing, organizing, analyzing to erasing.
Some processing activities include:
- Data cleaning and preprocessing
- Data analysis
- Data storage and retrieval
- Data erasure
Is My Business Required to Do a RoPA?
If your organization is regularly conducting data processing activities, under the General Data Protection Regulation (GDPR), it is obligated to create and maintain a Record of Processing Activities or RoPA.
What are the 10 Data Processing Activities?
Data processing includes several activities or steps, including:
- Data collection: Gathering data from different sources such as databases, online forms, etc.
- Data preparation: Ensuring data quality by detecting and correcting errors
- Data transformation: Reorganizing the data in a different format (better suited for analysis or sharing)
- Data aggregation: Creating a summary of data from different sources
- Data analysis: Using different techniques (machine learning, data mining, statistics) to analyze data
- Data visualization: Graphically representing data (charts, tables, graphs…)
- Data storage: Storing the data in secure storage systems or databases for easier access
- Data retrieval: Accessing stored data from storage systems
- Data reporting: Creating reports and analyzing summaries for stakeholders and decision-makers
- Data backup and archiving: Storing and archiving historical data for regulatory compliance