Records of Processing Activities:
Why the RoPA should be at the center of your privacy management efforts.
As a GDPR compliant company, you should record every piece of personal data that is being processed. Processing personal data means not only collecting it, but also – amongst others – aggregating, analyzing, sorting, distributing, storing, viewing, and deleting it. The registration of that processing should be centralized in the Records (or sometimes Register) Of Processing Activities, also known as ROPA.
Whether you’re a processor or a controller, in most cases you’re obliged to maintain a ROPA. It should contain the following aspects:
- the name and contact details of the controller or processor
- the purposes of the processing;
- a description of the categories of data subjects and of the categories of personal data;
- the categories of recipients
- transfers of personal data to a third country or an international organisation with, in some cases, the documentation of suitable safeguards;
- the retention period of the different categories of data;
- a general description of the technical and organisational security measures.
Benefits of a RoPA
1. Compliance with GDPR – and beyond
The thoroughly filled out ROPA creates transparency within the company by demonstrating a commitment to protect the data subject’s (this could be customers, employees, or any other identifiable natural person) personal data and hence guaranteeing their privacy. It is a key tool in convincing the Supervisory Authority of your accountability in the processing of personal data.
While filling out the ROPA of your company you will get insights in compliance with the data minimalization principle of the GDPR. You will easily detect superfluous personal data and remove those data. This helps you focus efforts on processing and securing only the necessary personal data which in return can lead to cost savings.
2. Data inventory and data flow mapping
The scope of the data processing activities (from collection to destruction) can be retrieved in a single place. You create an up-to-date data inventory and data flow map.
3. Better inter-team communication
Every department that processes personal data must evaluate its business processes to document their processing activities in the ROPA. By doing this exercise, you create more awareness of your processes which may lead to implementing more efficient workflows. As the processes become more clear, the employees will get a better understanding of what information can be found at which department. This improves the communication in an organization and increases the organization’s productivity.
4. Cost savings
You can easily detect overlap between data processors or interdepartmental services and remove the possible duplicates. You gain more insights and confidence in your company’s processes which helps you identify storage needs and requirements in a more efficient way.
5. Avoid fines and reputational damages
By not having or keeping your ROPA up-to-date at a granular level, you risk to be fined. Nevertheless, reality shows that the brand damage organizations experience from breaching the GDPR exceeds by far the financial value of the fine.
Why is the RoPA the center of your business?
The ROPA connects every part of the GDPR:
- Your ROPA should mention the stakeholders you collaborate with that process (a part of) the personal data. In RESPONSUM, you can add the agreements and vendor assessments to the stakeholder in question.
- You easily identify where your data is being transferred to, which may need a Transfer Impact Assessment or TIA.
- You can detect the weaknesses or processes that likely result in a high risk. This indicates that you may need to perform a Data Protection Impact Assessment or DPIA. You can perform a DPIA on a process, or on a project that includes several processes.
- Whenever there is an incident or a data breach, you can easily identify which process(es) is affected, the concerned departments, data subjects and the measures already taken.
- By creating a ROPA, you become aware of the glaring gaps in your processing. TOMs help you to implement security measures to prevent incidents or breaches. If you integrate the outcome of your ROPA into your software development cycle, you can improve your data protection by design practices.
- Even beyond the legal and policy compliance, it gives you deeper insight in your data, activities and data sharing with partners. Data is the new oil for any business. The greater your understanding of your data, the better your chances of utilizing that data effectively to drive business goals.
- Since every process has its concerned departments mapped, you can target them with specific awareness e-learnings or phishing campaigns.
- When a data subject requests to perform his rights, you can easily find in which processes its data has been used and which information management system(s) stores its data.
- Technical and Organisational measurements defined in a ROPA are also bundled in your policies and procedures.
In conclusion, the ROPA is truly at the heart of GDPR compliance management and should be one of the key points DPOs want to keep in order for efficient and effective GDPR compliance.
If you’re interested in automating your ROPA and linking it to the other GDPR requirements, book a quick call with one of our privacy experts, or request a demo!