What is a Record of Processing Activity (RoPA) and why does it matter?

Did you know?

In 2025, the Polish Data Protection Authority fined a Polish bank €132,000 after it failed to document a key profiling activity in its Record of Processing Activities (RoPA) and did not carry out a required Data Protection Impact Assessment before processing took place.

Regulators found that although the bank used customer data to profile individuals for creditworthiness assessments, this processing activity was not recorded in its RoPA, a core accountability obligation under Article 30 of the GDPR.

This case highlights the importance of understanding and documenting how personal data is used across an organisation.

Why good data protection matters

Effective data protection starts with knowing what personal data we use, why we use it, and how we safeguard it. It is not only about avoiding regulatory penalties; it is about embedding responsible data management practices and demonstrating transparency and accountability throughout the organisation.

What is a Record of Processing Activities (RoPA)?

A Record of Processing Activities is the organisation’s central record of how personal data is handled. It provides a structured overview of:

• what personal data is collected;

• how and why it is used;

• who the data relates to;

• who it is shared with (if applicable);

• how long it is retained; and

• how it is protected.

In simple terms, RoPA is a map or inventory of personal data across the organisation. It helps us understand what data we hold, how it flows through the business, and how it is managed in line with data protection requirements.

Why do we need RoPA?

RoPA is not a tick-box exercise. It plays a critical role in protecting individuals’ data and managing organisational risk.

Key reasons it matters include:

• Legal compliance – maintaining RoPA is a formal legal requirement.

• Accountability and transparency – data protection laws require organisations to demonstrate control over their data processing activities, and RoPA is a primary means of doing so.

• Risk management – documenting processing activities helps identify privacy risks early and implement appropriate safeguards.

• Supporting individuals’ rights – RoPA enables accurate and timely responses to requests such as access or deletion.

• Regulatory readiness – regulators often request RoPA as a first step during audits or investigations.

Even if you are not directly responsible for maintaining RoPA, your day-to-day handling of personal data feeds into it.

The legal requirement

Under Article 30 of the UK GDPR and EU GDPR, organisations are legally required to maintain a Record of Processing Activities and make it available to supervisory authorities on request.

Importantly:

• this obligation applies to most organisations, not only large enterprises;

• it covers both controllers and processors; and

• failure to maintain RoPA may constitute a compliance breach.

Similar record-keeping requirements are increasingly reflected in data protection laws worldwide, underscoring a global focus on accountability and demonstrable compliance.

Why this matters beyond the privacy team

RoPA is not just a privacy document, it reflects how personal data is actually used across the organisation. Changes to systems, tools, projects, or ways of working can all affect data processing, for example:

• introducing a new system or tool;

• changing how data is used;

• transferring personal data across borders; or

• sharing data with a new third party.

Each of these may require updates to RoPA and, in some cases, additional risk assessments.

In summary

• RoPA is a legal requirement under UK GDPR, EU GDPR, and many global data protection laws;

• it helps organisations understand, manage, and protect personal data;

• it supports transparency, accountability, and trust;

• due diligence is essential for all systems and processes involving personal data; and

• everyone has a role in keeping records accurate and up to date.