The damage caused by cyber attacks in 2022 till now is estimated to be around a whopping $6 trillion. The concern over data protection and GDPR Requirements is increasing for both individuals and corporations.
While regulatory authorities are taking consistent measures to ensure data security, such laws and guidelines are only as effective as your application of them.
One such regulatory requirement is RoPA, introduced by Article 30 of the General Data Protection Regulation (GDPR).
It holds companies accountable for the activities performed by them. But what does it entail and how can you follow it to ensure your data protection? Let’s find out.
RoPA: 5 Rules to keep your business data protected
With the rise of big data and the digital revolution, the need for data security is imminent. The GDPR is a data protection regulation that lays out laws and frameworks to regulate the operations of the members of the EU (European Union) and ensure the data protection of individuals and corporations alike.
RoPA is a requirement laid out by Article 30 of GDPR that states that a controller is required to maintain a thorough record of activities that are performed under its responsibility. It is an internal document every company is required to maintain under the governance of GDPR Requirements.
Given below are some of the rules and regulations as per RoPA that will help keep your business data protected.
1. Understand the rules of data privacy
To be able to enforce compliance with the required regulations and ensure the safety of your database, you need to understand the regulations required of you in clear terms. It can often feel daunting to simplify into technical terms.
You can learn about RoPA here in detail and understand how it applies to your company’s processes. In simple words, it says that every controller and their representative needs to maintain a thorough record of activities processed under their responsibility.
It means that all your data processing activities should be recorded in one place that can be used as a reference as and when needed. You will need to continually update this record for internal or external audits.
Such a document ensures that all data processing activities conducted by a company are following the data protection legislation laid down by the GDPR. It also helps paint a bigger picture of the data processing conducted by you for audit purposes.
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a) What is included in RoPA?
Given below are the details your RoPA document should contain. For each entry you make about the data processing conducted by you, make sure to record the following details:
- Details of the data controller such as their name and contact information. This also includes the joint controller, the collector’s representative as well as the data protection officer.
- Categories for the data subject.
- Types of personal data being recorded.
- Purpose of processing this particular data.
- Categories for past data recipients.
- Categories for future data recipients.
- Data is transferred, if any, to a third party. It could be a third country or international organization.
- Description of the security measures being taken to protect the data.
- Time limit regarding the erasure of the data entry.
In addition to that, data processes are also required to maintain records on behalf of the controller. Their RoPA should include:
- Name and details of each processor.
- Name and details of every controller that has engaged with them to work on and process data.
- Categories of the data processed.
- Data is transferred, if any, to a third party. It could be a third country or international organization.
- Description of the security measures being taken to protect the data.
b) Do you need to maintain RoPA?
The answer is probably yes. This is because it is required to be maintained by companies that deal with data frequently. And most companies in today’s digitized world rely heavily on data to function properly.
As per GDPR, companies that have over 250 employees are required to maintain a RoPA document. Companies that have less than 250 employees but frequently process data are also required to maintain it.
Additionally, if your processing activities may result in a risk to the rights of the data subjects, you process special categories of data such as race, gender, and religion, or your processing is related to criminal offenses, you are required to maintain a RoPA.
It is advisable that you maintain a RoPA regardless of whether you fall into these categories or not. Having an updated record on hand helps your cause in case you ever have to dabble in those activities or unknowingly do so.
The only companies that don’t have to worry about maintaining a RoPA record are the ones that dabble in data processing only occasionally.
2. Maintain both digital and physical records
GDPR requires you to maintain your RoPA in a written format, be it physical or electronic. Most companies opt for electronic records as they are easy to edit, with Microsoft Excel being the most popular choice for a RoPA document.
That said, it is advisable to store your RoPA document in physical form from time to time. Now, the document will be changing every day as you add, remove, and edit entries. So, you cannot keep a physical copy of every day’s document.
But you can surely create a physical copy, say, at the beginning or end of every week or month. It helps keep a tangible, physical record to go over when the digital one changes continually.
It captures your processing activities in a moment in time when they keep changing. You can even compare two different records to analyze the pattern, rate, or direction of your processing activities.
3. Keep the record up to date
The GDPR requires your RoPA record to be up to date. This means you need to update at every point regarding a procedure: when you begin it, any change that occurs to it, and when you finish it.
However, it can often be a daunting task to keep updating the document. You may even miss out on some entries, or record them incorrectly. This increases the chance of mistakes, risking the audit that rests on the RoPA document.
To tackle this issue, you can appoint an employee solely to caretake RoPA bookkeeping responsibilities. Companies often appoint a data protection officer (DPO) to look after the RoPA procedures, including correctly recording the process.
This serves the dual benefit of ensuring the RoPA document is constantly up to date as well as any issues regarding the recording of entries are immediately dealt with. You may not opt for a DPO and simply assign another employee the task.
4. Only show the RoPA document to relevant parties
The rules and regulations set by the GDPR state that you are required to show your RoPA to any supervising authority when they request it. When and how they can ask for it is usually detailed in the records of consent, company contract, and privacy policies along with any other relevant document.
The most common time when a RoPA document is requested of you is during an audit. Additionally, it may also be requested for a special project that deals with data protection or processing.
In emergency cases, it may be as you in case of a data breach. Whenever you are requested to present your RoPA document, ask for written permission to follow through with it. Also, make sure that the party is a relevant one who is authorized to ask you of it.
This is important because your RoPA document contains sensitive user data that can be grievously misused if it falls into the wrong hands. It is extremely important to make sure the authority asking for it is legit and has genuine grounds to request it from you.
5. Manage and store your information efficiently
As discussed above, most companies fall in the category of having to maintain a RoPA record. The only ones that aren’t required to maintain one are the ones who indulge in data processing only occasionally. That means most companies have large databases to manage.
Using a data management tool can help organize your database for more efficient use. You can organize data by fields such as gender and age groups to find users quicker. It also helps store data better.
You can create backups in electronic form. In case of data breaches or data being compromised, you will have a backup to fall back on instead of starting from scratch. Such tools also help update your RoPA document with ease.
Conclusion
Data processing has become an integral part of our digitized world. Companies are engaging in data processing in some way or another daily.
A RoPA document helps companies track their data processing activities along with maintaining a neat record for audit purposes.
It helps make organizations accountable for data protection and user privacy. It also makes sure they adhere to the compliance set by the GDPR requirements to ensure regulation and security.
Let us know in the comments what you think is the best way to comply with the RoPA regulations set by the GDPR requirements and ensure one’s data security.
About the Author- Dr Muddassir Ahmed
Dr MuddassirAhmed is the Founder & CEO of SCMDOJO. He is a global speaker, vlogger and supply chain industry expert with 17 years of experience in the Manufacturing Industry in the UK, Europe, the Middle East and South East Asia in various Supply Chain leadership roles. Dr. Muddassir has received a PhD in Management Science from Lancaster University Management School. Muddassir is a Six Sigma black belt and founded the leading supply chain platform SCMDOJO to enable supply chain professionals and teams to thrive by providing best-in-class knowledge content, tools and access to experts.
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