Οδηγός: Αρχείο Δραστηριοτήτων Επεξεργασίας

Article 30 GDPR requires every data controller and data processor to maintain a record of processing activities. While there is a limited exemption for organizations with fewer than 250 employees, this exemption is so narrow that it almost never applies in practice: it only covers organizations that process personal data occasionally, do not process special categories of data, and do not process data that could pose a risk to individuals. In practice, virtually every organization that handles employee data, customer data, or website visitor data needs a RoPA. This means the vast majority of your clients — regardless of size — are legally required to maintain one. As an external DPO, you are typically responsible for creating, maintaining, and updating RoPAs for each of your clients. With 10-20 clients, this can quickly become a significant administrative burden if managed manually.

Article 30(1) specifies the mandatory contents for controllers. Each processing activity entry must include: the name and contact details of the controller and DPO, the purposes of processing, a description of the categories of data subjects and personal data, the categories of recipients, transfers to third countries including safeguards, envisaged retention periods, and a general description of technical and organizational security measures. For processors, Article 30(2) requires a slightly different set of information: the name and contact details of the processor and each controller on whose behalf processing is carried out, the categories of processing carried out, transfers to third countries, and where possible, a description of security measures. Many supervisory authorities recommend going beyond the minimum requirements. Adding the legal basis for each processing activity, the source of the data, and whether automated decision-making is involved makes your RoPA more useful as a compliance management tool — not just a checkbox exercise.

The most frequent mistake is treating the RoPA as a one-time project rather than a living document. Processing activities change — new software is introduced, data flows are modified, retention periods are updated. A RoPA that was accurate in January may be outdated by March. Another common issue is inconsistent granularity. Some DPOs document every single system as a separate processing activity, ending up with hundreds of entries that are impossible to maintain. Others group everything into five or six broad categories that lack the specificity supervisory authorities expect. The right level of granularity typically means 15-40 processing activities for a medium-sized organization. Finally, many DPOs manage RoPAs in Excel spreadsheets — which works for one or two clients but breaks down at scale. No version control, no review reminders, no structured fields, and no way to generate audit-ready exports. This is where dedicated tools make a measurable difference.

The key to efficient RoPA management is structure and automation. Start with industry-specific templates that pre-populate common processing activities — an e-commerce company and a healthcare provider have very different processing landscapes, but companies within the same industry share 70-80% of their activities. Set review dates for each processing activity. Most supervisory authorities expect annual reviews at minimum, but critical processing activities should be reviewed whenever a significant change occurs. Automated reminders ensure nothing falls through the cracks. Version control is essential for accountability. When a supervisory authority asks about a specific processing activity, you need to show not just the current state but the history of changes — who updated what and when. This audit trail protects both you and your client. For external DPOs managing multiple clients, a multi-tenant tool like Trustee.eu eliminates the overhead of maintaining separate systems. You can use the same templates across clients in the same industry, generate audit-ready PDFs with one click, and see at a glance which clients have overdue RoPA reviews.