Making your RoPA work for your business
Records of Processing Activities
Creating and maintaining Records of Processing Activities, is a core data protection obligation for many businesses, but it’s clear it’s an area many struggle with.
Our Privacy Pulse Report 2022 revealed this to be the top challenge facing DPOs and privacy teams.
It’s an area which was raised in the UK Government’s consultation on UK data law reform. Proposals included introducing a more flexible and proportionate approach to record keeping.
Currently, the level of detailed required under UK GDPR makes records time consuming to create. Maintaining these records over time as your business processing evolves requires resources and ongoing engagement from across the organisation.
However, even if the data reform proposals go through, it’s clear businesses won’t be able to rip up and disregard recording keeping activities.
Maintaining a central record of what personal data you hold, what it’s used for, where it’s stored, how its protected and who it’s shared with is a sensible and valuable asset for any organisation.
6 reasons why your RoPA should be a valuable asset
1. Risk awareness
Identifying and recording your business activities means you can fully understand the breadth and sensitivity of your data processing. This can help you to clearly identify where data protection risks lie, so you can establish priorities and fully get to grips with mitigating these risks.
2. Lawful processing
Confirming and recording which lawful bases you’re relying on for each processing task means you check you’re meeting the relevant conditions for this basis. Be it consent, contract, legitimate interests and so forth.
3. Personal data breaches
Your RoPA should be the ‘go to’ place if you suffer a breach. It can help you to identify what personal data may have been exposed and how sensitive that data is, who might be affected, which processors might be involved and so on. Helping you to make a rapid risk assessment (within 72 hours) and helping you make good decisions to mitigate risks from the breach.
4. Individual privacy rights
If you receive a Data Subject Access Request, your records can help to locate and access the specific data required to fulfil the request. If you receive an erasure request, you can quickly check your lawful basis for processing and see if the right applies.
With good records in place, you can be confident you’ve identified all the types of activities which need to be covered in your privacy notice.
6. Suppliers (processors)
Logging all your processors can support you in keeping on top of supplier management including due diligence, contractual requirements and international data transfers.
While many may not find documentation and record keeping much fun. Try and sell the benefits, get key stakeholders on board and bake it in to your routine business activities.