Record of processing activities
In short: The record of processing activities (RoPA) is an internal list in which a company documents which personal data it processes for what purpose.
In more detail: For each processing operation you state purpose, categories of data subjects and data, recipients, third-country transfers, deletion periods and technical safeguards. The duty in principle also applies to small businesses if processing is not merely occasional.
In Depth
- Example entries: user accounts, newsletter, order handling, support tickets, server logs, payment handling.
- Benefit: overview, basis for the privacy policy and for access requests.
- Maintaining: Update with new features and service providers.
- Template: Supervisory authorities provide samples.
- Showing: on request of the supervisory authority.
See also: Data processing agreement, Data protection impact assessment