Article 30 Records (RoPA)
Complete Guide for CCOs and DPOs
What are Article 30 Records?
GDPR Article 30 requires all organizations to maintain Records of Processing Activities (RoPA). This is a comprehensive record of all ways your organization processes personal data.
Legal Requirement: Article 30(1) for controllers and Article 30(2) for processors. Failure to maintain these records can result in fines up to €10 million or 2% of global turnover.
Quick Start Guide
- 1Navigate to RoPA section
Dashboard → Compliance → Article 30 Records - 2Create your first processing activity
Click "Add Processing Activity" and fill in the required fields - 3Auto-generate records (optional)
Use our AI-powered generator for common processing activities - 4Export for auditor or regulator
Download as CSV or include in compliance package
Article 30(1) Required Fields
Each processing activity must include:
1. Controller Details
Name and contact details of the controller (your organization)
2. Processing Purposes
Why you are processing the personal data
3. Data Categories
Types of personal data (names, emails, addresses, etc.)
4. Data Subject Categories
Who the data is about (customers, employees, etc.)
5. Recipients
Who you share the data with (processors, third parties)
6. Transfers Outside EU
International transfers and safeguards used
7. Retention Period
How long you keep the data
8. Security Measures
Technical and organizational measures (Article 32)
Legal Basis for Processing (Article 6)
You must identify the legal basis for each processing activity:
Art. 6(1)(a) - Consent
The data subject has given consent for specific purposes
Art. 6(1)(b) - Contract
Processing is necessary for performance of a contract
Art. 6(1)(c) - Legal Obligation
Processing is necessary to comply with a legal obligation
Art. 6(1)(f) - Legitimate Interests
Processing is necessary for legitimate interests (requires balancing test)
Common CCO/CPO Scenarios
📋 Preparing for GDPR Audit
Scenario: Supervisory authority requests to see your Article 30 records
Solution: Export complete RoPA as CSV → Include in compliance package → Provide to auditor
✅ Requirement: Must be able to produce records on request (Article 30(4))
🔄 Annual RoPA Review
Scenario: Quarterly or annual review of processing activities
Solution: Review all records → Update outdated information → Archive deprecated activities
✅ Best Practice: Review every 3-6 months or when significant changes occur
🆕 New Processing Activity
Scenario: Launching new product/service that processes personal data
Solution: Create Article 30 record BEFORE go-live → Trigger DPIA if high-risk → Document legal basis
✅ Requirement: Records must be maintained "at the time of processing" (Article 30)
Frequently Asked Questions
Do I need Article 30 records if I have fewer than 250 employees?
YES - The 250 employee exemption (Article 30(5)) only applies if:
- Processing is occasional (not regular)
- Processing is unlikely to result in risk to data subjects
- Does NOT include special category data (Article 9) or criminal data (Article 10)
⚠️ In practice, nearly ALL companies need Article 30 records because they process data regularly
What's the difference between controller and processor records?
Controller (Article 30(1)): Your organization determines purposes and means of processing
Processor (Article 30(2)): Your organization processes on behalf of another controller
💡 Tip: If you use services like AWS, SendGrid, or Stripe, you're a controller. Those vendors are your processors.
Can I use auto-generation or do I need manual entry?
Our platform offers both options:
- Auto-generation: AI suggests common processing activities based on your industry
- Manual entry: Full control over all fields for custom/unique activities
- Hybrid: Start with auto-generated records, then customize as needed
✅ All records are reviewed by your CCO/DPO before finalization
How often should I update Article 30 records?
Immediately when changes occur to processing activities
Quarterly as part of regular compliance review
Annually for comprehensive audit and verification
⚠️ Outdated records during an audit can indicate lack of compliance awareness
What format should I use for export?
GDPR doesn't specify a format. We provide:
- CSV: Machine-readable, import to Excel/Google Sheets
- Compliance Package: All 24 compliance files including RoPA
✅ Both formats include all 8 required Article 30 fields
Ready to Get Started?
Start maintaining GDPR-compliant Article 30 records today with automated workflows and audit-ready exports.