Article 30 GDPR - Records of processing activities
Frequently Asked Questions
Short answers to common questions about this provision. They are general information and not legal advice.
Article 30(1) lists the required content, namely the name and contact details of the controller and, where applicable, the joint controller, the representative and the data protection officer, the purposes of the processing, the categories of data subjects and of personal data, the categories of recipients including those in third countries, any third-country transfers with the safeguards documented for transfers under the second subparagraph of Article 49(1), and, where possible, the envisaged erasure time limits and a general description of the security measures referred to in Article 32(1).
Yes. Under Article 30(2) each processor, and where applicable its representative, must maintain a record of all categories of processing activities carried out on behalf of a controller, covering the contact details of the processor and of each controller for which it acts, the categories of processing, any third-country transfers and, where possible, a general description of the Article 32(1) security measures. The processor's record is shorter than the controller's because it mirrors the processor's more limited role.
Paragraph 3 requires the record to be in writing, including in electronic form. Under paragraph 4 the controller or processor, and where applicable their representative, must make it available to the supervisory authority on request, so the record functions as a standing accountability instrument rather than a public document.
Only partially. Paragraph 5 exempts enterprises and organisations employing fewer than 250 persons, but the exemption falls away if the processing is likely to result in a risk to the rights and freedoms of data subjects, if it is not occasional, or if it includes special categories of data under Article 9(1) or data relating to criminal convictions and offences under Article 10. Because routine processing such as payroll or customer administration is not occasional, the exemption is narrow in practice.
The record operationalises the duty in Article 5(2) and Article 24 to be able to demonstrate compliance, since it captures in one place the purposes, data categories, recipients, transfers, retention and security of each processing activity. Recital 82 confirms that the record exists so that controllers and processors can demonstrate compliance and cooperate with the supervisory authority.