How Records of Processing Activities (ROPA) Can Benefit your Business was written for Playlouder by a contributing author. Please note that contributing opinions are that of the author. They are not always in strict alignment with our own opinions.
Quite recently, the GDPR introduced the Records of Processing Activities (ROPA) requirements for better monitoring organizations on how they process private data and make better use of it.
Before the GDPR was created, organizations didn’t have organized guidelines about using and sharing personal data, so data privacy risks were far more challenging to manage. However, the GDPR has intervened and hopes to ensure that organizations follow better rules about using private data.
So, how can ROPA benefit your business? Let’s read more in this article to find out!
What is ROPA?
The first question is, “What is ROPA?” ROPA was initially introduced by the GDPR when they set new terms and rules that set the bar higher for data privacy worldwide. ROPA is one way of ensuring your business is complying with the regulation standards.
Think of ROPA as a summary of your data processing practices. It’s one document that outlines your business data processing activities. Some processing examples include marketing, HR, third-party activities, and others that process personal data.
After all, the GDPR does the legal processing activities for most businesses. It’s a super helpful tool for self-auditing. Understanding these records is mandatory for companies, and what is even more important is to identify the risks associated with them.
What is mandatory to include under ROPA?
ROPA is a record of process activities that data controllers and processors process. Here are the essential details you need for ROPA documents within your business:
- Data subject categories
- Name, business details, data processors, and controller's contact details
- Purposes of data processing
- Personal data transfers for a third country or international organization
- Security measures practiced and outlined within a company or organization that is related to a processing activity
- Categories of recipients whose personal data will be disclosed with
A ROPA record will list data processing activities, offering detailed information on each item and the abovementioned ROPA requirements.
Why is ROPA so important?
While increasing privacy regulation focus, ROPA maintenance is more vital than ever for most organizations. This is because ROPA doesn’t only serve as complying with the GDPR but also helps businesses perfect GDPR compliance. In addition, ROPA maintenance helps organizations better prepare to comply with updated data privacy laws when introduced.
Larger companies will create individual ROPA documents for departments. Smaller companies will usually begin ROPA documentation only by using a spreadsheet. However, as the company keeps growing, the ROPA documentation and maintenance will continue to leverage.
Keep in mind that it’s mandatory to keep your ROPA updated. In larger companies, privacy teams must be much more active and help. Nevertheless, keeping ROPA up to date is essential for complying with data privacy policies. Therefore, you need to make the necessary adjustments as updates occur and check up on ROPA now and then.
6 Benefits associated with ROPA
Identify data redundancies
When creating your ROPA, you can see different types of data being saved and updated at other times and locations, making it impossible to identify which records are the most complete and accurate. However, you can build a source of truth after identifying these redundancies, allowing you to get more value from your data.
Data flow mapping and inventory
First, it allows your organization to scope its data collection activities in one place. You may find out that several teams are handling similar or the same processing activities in multiple areas of your codebase. Therefore, you can identify an overlap between data processors which can be simplified.
What can you do? You can simply automate the data inventory process, which might keep your data map flow and inventory up to date, even more than ROPA requires.
Data subject requests
If someone requests access or their data to be deleted, ROPA helps you identify in which category the data is located and how it’s processed. This information can be increasingly beneficial for your business as it grows.
Enhanced internal communication
Collecting the necessary data for ROPA can help improve the effectiveness of your business process. Setting up a ROPA will help set up the process for staying up to date with it and improving internal communication within your organization.
Documentation created around ROPA management also helps stakeholders understand how data will be used within a business. After all, the world revolves around data, so your business needs to stay fully updated.
Preparing for future privacy regulations
Even if the GDPR doesn’t require you to complete a ROPA, it’s still considered a great way to prepare for any adaptations you’ll need to make as privacy laws change.
Provides you with self-audit
A self-audit can help identify areas in your security measures that you may haven’t paid enough attention to. For example, audits usually find holes in control access, data retention practices, and even outdated encryption techniques. So, if you incorporate ROPA in your everyday operations, you have a good chance of improving your DevSecOps.
Who can maintain ROPA?
Usually, larger businesses with more than 200-300 employees will use ROPA. However, even with fewer employees, you still need to keep records. Here’s how you maintain ROPA:
- You have to process data more often
- You process specific categories of data, including religion, gender, race, etc.
- You process data relating to criminal activities.
How should you format ROPA?
According to article 30 of the GDPR, you must have written records, including those noted electronically. Electronically written records are ideal because they easily add or remove information within businesses. Usually, most companies will maintain ROPA by using a spreadsheet, but there are many other formats you can use too.
When should you update your records, and who needs to see them?
In order to stay updated with the GDPR standards, it’s best to keep ROPAs updated more frequently.
Additionally, you can consider hiring a data protection officer (DPO) to make things easier. The DPO will handle your ROPA procedures and save you time, protecting you from any work duplications.
What kind of impact has ROPA left?
Today, data is the backbone of many businesses. The greater your understanding of your data, the more effective it may be for driving business goals. However, considering data privacy importance, you must have the correct information, such as the “What, who, why, where, when, and how.”
ROPA plays a significant role in this kind of data management, and it provides you with the necessary information regarding data privacy. Additionally, ROPA can align your data privacy requirements and help you incorporate the proper data management practices.
Also, during the creation stage of ROPA, businesses will usually eliminate data redundancies and data that doesn’t need processing. Considering the amount of data an organization collects, it’s no surprise that the same data is present in one area. However, ROPA helps eliminate this issue and fully optimizes your business data.
So, ROPAs' impact extends beyond legal and policy compliance. While you may know that creating ROPA is an essential part of an organization’s data privacy compliance plan, it can also bring much better transparency and in-depth insights regarding data, activities, and data sharing with partners.
Our hope is that by reading this article about ROPA, you are more aware of its impact on businesses at large and potentially your own business. Of course, data is essential to keep up with during the digital age; however, let’s not forget that managing your data processes also matters.