After the General Data Protection Regulation (GDPR) became active back in 2018, it brought a plethora of new regulations and guidelines to companies on how they have to handle the data of their customers. ROPA is one such regulation. Article 30 of the European Union’s GDPR requires companies and bodies to create and maintain a record of all the processing activities they perform.
What is ROPA?
ROPA stands for Record Of Processing Activities for Data Privacy and Security. It is an overview of all the data processing activities a company is required to maintain (Both controllers and processors). These records must be readily available and must be provided upon the request of a supervising authority.
A ROPA must include the following:
- Names and contact details of controllers/joint controllers/controller’s representative and the Data Protection Officer.
- The different types of data subjects.
- The different types of personal data.
- The recipients to whom the data will be or has been disclosed to.
- The timelines of deletion of the data.
- A description of organizational and technical measures being taken to keep the data safe.
What are these processing activities mentioned under ROPA?
A ROPA requires a company to list every single data processing activity that takes place in the organisation. Diving deeper a company will have to provide and answer the following questions in a ROPA:
- Where is the data being used exactly?
- What are the technical measures your company is taking to protect data?
- What are the organisational measures your company is taking to protect data?
- Who is being affected by the processing of the data you are collecting?
- Who are the data processors?
- What is the basic risk analysis of all these data?
What is the need for ROPA?
- ROPA demonstrates that your company is compliant with GDPR.
- It also creates a good impression on your customers, clients and supervising authorities.
- It also gives the message that your company is an organised one.
- It is a compulsory document as mandated under Article 30 of the GDPR.
- It enables the government bodies to do their functions well.
- It helps the company in efficient data collections and limits them from collecting bulk data.
- It allows a business to predict the risky areas and plan out steps on how to address them.
How to start creating and maintaining a ROPA?
Usually, it is the heads of the department who are responsible for creating or contributing in the process of creation of a ROPA since they overlook all the data that is being collected. The process is guided by the expertise of the Data protection officer. Companies take the following steps in the process of creation of a ROPA:
- Get directly in touch with the HR, Marketing, Customer Service teams because they are concerned with data collection very closely. Other than them the Information Technology teams will hold the security and more technical data.
- Refers to the company’s paperworks suc as the data protection policies, data protection contracts, data sharing agreements.
- The ROPA can turn out to be a difficult document to create thus it is advised that you approach it in a systematic manner to ease the flow of documents and data.
- Make sure the ROPA is updated regularly. In practice the ROPA is like a living document and it needs to be updated as the processing activities proceed.
What happens if you don’t maintain a ROPA?
In the event that your administrative body, the ICO for UK based organisations, requests to see your ROPA and you can’t supply it, you hazard the standard greatest fine which applies to encroachments of regulatory prerequisites under GDPR. This could add up to €10 million (comparable in UK Sterling) or 2% of the absolute yearly worldwide turnover (from the first year) whichever is higher.
In truth, it’s unimaginably impossible that you’ll be hit with a multi-million pound fine for not having a ROPA, yet in case you are dependent upon an examination it won’t be an extraordinary beginning in the event that you can’t outfit the ICO with your Record of Processing Activities at the start.
Making the record without any preparation is the crucial step; however, whenever it’s done you have a living report which shouldn’t need a similar degree of work from that point on to keep it refreshed on a regular basis. ROPA is a great tool to help your business grow and maintain a good reputation in the market. Therefore, the more information you have about your data, the more quickly and effectively you can use it to accomplish your business objectives. Whether needed or not, forming and maintaining a ROPA provides your business with a centralized repository source for responses to important questions about personal data: what, who, why, where, when, and how. Your ROPA’s observations lay the groundwork not just for complying with data privacy regulations, but also for enforcing strict strong data management practises across the firm.