PRIV- 27 – Record of Processing Activities

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What is this control about?

Implementing the control ‘Record of Processing Activities’ is crucial for ensuring compliance with data protection regulations and demonstrating accountability in data processing activities. This control involves maintaining a comprehensive and up-to-date record that outlines the organization’s data processing activities and the personal data it handles.

Available tools in the marketplace

Tools:
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Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

Control implementation

Here are some guidelines to implement a Record of Processing Activities:

  • Data Inventory: Begin by conducting a comprehensive data inventory across the organization. Identify all systems, databases, applications, and processes that handle personal data. Work closely with data owners, data custodians, and relevant departments to gather accurate information.
  • Data Mapping: Create a data map that outlines the flow of personal data throughout the organization. This map should detail the sources of data, types of data, data recipients, data transfers, and any third-party involvement. This step will help you understand the complete lifecycle of personal data.
  • Data Categorization: Categorize the personal data based on factors such as data subjects, data types, processing purposes, and legal bases for processing. This categorization will aid in organizing and managing the records effectively.
  • Data Collection Template: Design a standardized data collection template to record processing activities. The template should capture essential information such as the purpose of processing, data categories, data recipients, data transfers (if any), data retention periods, and security measures in place.
  • Identify Responsible Parties: Assign responsibilities to individuals or teams responsible for updating and maintaining the record of processing activities. Clearly define their roles and access permissions within the data collection system.
  • Centralized Repository: Establish a centralized repository or database to store the records of processing activities. Ensure that the system is secure, and access is restricted to authorized personnel only.
  • Regular Updates: Set up a process for regular updates and reviews of the records. Schedule periodic reviews to verify the accuracy and completeness of the information. Update the records whenever there are changes to data processing activities.
  • Privacy Impact Assessments (PIAs) and Data Protection Impact Assessments (DPIAs): Integrate the information from PIAs and DPIAs into the records of processing activities. These assessments provide valuable insights into the risks associated with data processing and help ensure appropriate safeguards are in place.
  • Data Protection Officer (DPO) Involvement: Involve the Data Protection Officer in the implementation and maintenance of the records. The DPO can provide expertise and ensure compliance with data protection regulations.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

  • Provide your Record of Processing Activities Register that contains detailed information about all processing activities carried out by the organization. This should include the purpose of data processing, categories of personal data, data recipients, data transfers, data retention periods, and any third-party involvement.

Evidence example

For the suggested action, an example is provided below:

  • Provide your Record of Processing Activities Register

Use the Record of Processing Activities Example

 

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