GDPR introduced the Records of Processing Activities (ROPA) requirements to drive better accountability from organizations with their use of personal data. Before GDPR, organizations didn’t track how they used and shared personal data, making data privacy risks impossible to comprehend. Now GDPR mandates that organizations create and maintain essential information about how an organization uses personal data.
What Are Records of Processing Activities (ROPA)?
In short, ROPA is a register that documents all the processing activities done on all personal data by an organization. ROPA must track information such as the purpose of processing, details about the parties to whom data will be disclosed, data retention duration, and other necessary details as mentioned under Article 30 of GDPR.
It is important to distinguish between ROPA and a data asset register or data inventory. Your ROPA offers insight not only into your organization’s data but also, importantly, focuses on how and why that data is used.
What Are the Mandatory Inclusions Under ROPA?
Your ROPA serves as a comprehensive list of all the processing activities performed by data controllers and data processors. The following are the mandatory details for every ROPA document maintained within an organization:
- Name and contact details of data controllers and data processors within the organization
- The purposes of data processing
- Retention schedule for storing each data category and time limits for erasure
- The categories of data subjects
- The categories of recipients to whom personal data has been or will be disclosed
- Personal data transfers to either an international organization or a third country
- The security measures outlined and practiced within the company or organization related to each processing activity
A comprehensive ROPA document lists every data processing activity and offers detailed information on each item included in the mandatory ROPA content list as described above.
The Importance of ROPA
In light of the increasing focus on privacy regulations, ROPA creation and maintenance is now more important than ever for organizations. ROPA not only serves as proof of GDPR compliance, but it helps businesses and organizations align with GDPR laws. ROPA maintenance can help businesses be better prepared to align with new data privacy regulations as and when they are introduced.
Larger organizations typically create individual ROPA documents for each department or individual streams of business. These are then compiled into one enterprise-level record. Smaller organizations often begin their ROPA documentation using a simple spreadsheet. As the organization grows, ROPA documentation and maintenance will have to be scaled up.
With stringent fines and detailed requirements, it is necessary to keep your ROPA up to date at a granular level. In a large organization, privacy managers and compliance teams need the help of data teams. As data stewards and engineers, you may be accountable for maintaining ROPA. Keeping your ROPA updated is an important step to ensure compliance with privacy policies. Therefore, you must make the necessary updates as changes happen. As a best practice, you should review and refresh your ROPA every quarter.
ROPA’s Impact Beyond Data Privacy
The importance of ROPA extends well beyond just legal and policy compliance. While creating ROPA is a necessary part of any organization’s data privacy compliance plan, it can also bring greater transparency and a deeper insight into their data, activities, and data sharing with partners.
In present times, data is gold for any business. The greater your understanding of your data, the better your chances of utilizing that data effectively to drive business goals. However, given the growing importance of data privacy, it is equally important that you have accurate information on the “what, who, why, where, when, and how” of personal data processing and storage within your organization.
ROPA can play an active role in Data Management, as it provides you with one source for critical information on personal data. In addition, your ROPA can help you align your organization with mandatory data privacy requirements and help you establish robust organization-wide Data Management practices.
Often in the process of creating ROPA, businesses identify data redundancies and unnecessary data processing. Given the sheer amount of data collected and stored by an organization, it is not uncommon for the same data to be present in several places. Data duplication can reduce the efficiency and accuracy of your data processing and data usage. ROPA can help you identify these unintentional data redundancies and help you optimize your business data.
On a Final Note
The business environment is continuously changing. New tech advances and new compliance and regulatory rules and practices, such as privacy laws, add to this churn. In light of these changes, mandatory compliance regulations such as ROPA can help businesses become more compliant and be ready for future changes.