Is Data Mapping & RoPA, one and the same thing?


Data mapping and Record of Processing Activities (RoPA) are two terms that are generally used interchangeably in the privacy domain. Those aware of these terms tend to get confused when differentiating the two. Both terms define two different concepts altogether. However, both concepts form an essential part of data protection and privacy today, especially concerning GDPR compliance. 

What is Data Mapping? 

Data mapping is a process wherein three significant questions are dealt with essentially, and they are- 

1. Why do you process data? 

2. What data do you process? 

3. Where do you process data? 

Data mapping is the process of documentation which helps the organisation to answer simple questions such as why-what and where about the data which they have collected and processed, as these questions not only help the organisation that is collecting the users’ data but it is also resourceful during the audits by authorities in order to understand about the data and its life cycle. In simple words, we can say that data mapping helps the organisation to know about their data’s ins and outs, right from the beginning till the end. 

Data Mapping & GDPR 

Surprisingly, data mapping is not mandatory as per the GDPR, but the same is encouraged by every data protection professional, as it allows the organisation or business to track down the data flow, which indeed is quite helpful while responding to a data subject access request (DSAR) as the same needs to be responded to within 30 days. Since the data subjects have the right to access their personal data, it becomes the sole responsibility of the data controller to respond to such requests without causing any undue delay, and delivering them their personal data on time. This could only be possible if the data controller keeps or has a document in place pertaining to the personal data of all the users which were processed throughout the time. Such a document needs to be updated regularly. 

 What is RoPA? 

Article 30 of the GDPR mandates the use of RoPA. It is the recording of all the processing activities in which the business/organisation are involved. The RoPA discusses these- 

1. The purpose of processing personal data; 

2. The details of third parties with whom the personal data of the users’/data subject is disclosed; 

3. The retention period of such personal data; 

4. Details about the safeguards which are in place in order to protect such personal data of the data subjects. 


1. RoPA is mandatory for every organisation and business which has over 250 employees or if such business or organisation’s processing activities are data intensive.  

2. Data-intensive means- how often the business/organisation processes personal data and in how much volume such data is being processed. 

3. Even when such processing of personal data puts the data subjects at risk, RoPA becomes essential. 

4. In cases where the data being processed is sensitive in nature, RoPA becomes essential. 

It is essential to note here that data mapping is a wider concept as it covers a detailed overview of how the data is stored and how it flows in the organization. On the other hand, a RoPA gives us an overview of how the data is used by the organization and how the organization works to ensure the protection of such data in order to maintain privacy.  

Lastly, having a data map helps the organization to create a RoPA much more efficiently as compared to when there isn’t a data map available. As the requirements in the RoPA are more or less fulfilled by data mapping, hence we can conclude this by saying that a RoPA is a part of data mapping.

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Curated by: Prajwala D Dinesh, Ritwik Tiwari, Ayush Sahay


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