20 Jun New RoPA guidance published by the Data Protection Commission Ireland
The Data Protection Commission – the Irish supervisory authority for the General Data Protection Regulation (GDPR) – recently published a new guidance note on records of processing activities under Article 30 of the GDPR (RoPA).
The new guidance serves as a helpful tool for any organisation required to maintain RoPA. It includes not only a list of ‘dos and don’ts’ organisations can refer to when preparing and maintaining their RoPA, but also two templates in a spreadsheet format.
Moreover, the guidance alerts organisations to practices they should refrain from, including where the RoPA contains insufficient details – such as hyperlinked documents rather than listing information (as required) – that may later not be accessible to the supervisory authority.
As mentioned in the guidance itself, well maintained RoPA serve as a measure to demonstrate the organisation’s compliance and is one of the means by which data controllers can demonstrate and implement the principle of accountability set out in Article 5(2) GDPR.
The new guidance was announced by the DPC’s deputy commissioner on 19 April 2023 and can be found here.
The guidance is particularly helpful for organisations that are required to appoint an Article 27 representative under GDPR and/or UK GDPR. The EU and UK representatives serve as a point of contact for data subjects and supervisory authorities on behalf of organisations not established in the EU and/or the UK, but are doing business with EU and UK clients. As part of their duties, EU and UK representatives are tasked with holding organisations’ RoPA securely. The responsibility for having RoPA in place, however, stays with the organisation.
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