Art.30 Records of processing activities
Maintain a written, including electronic, record of processing activities under the controller's responsibility containing the name and contact details of the controller, any joint controller, the representative and the data protection officer, the purposes of the processing, a description of the categories of data subjects and of personal data, the categories of recipients including those in third countries and international organisations, any transfers to a third country or international organisation with that destination identified and, for transfers under the second subparagraph of Article 49(1), the documentation of suitable safeguards, the envisaged time limits for erasure of each category where possible, and a general description of the Article 32(1) technical and organisational security measures where possible. A processor must maintain an equivalent record of the categories of processing carried out on behalf of each controller. Make the record available to the supervisory authority on request. The obligation does not apply to an organisation employing fewer than 250 persons unless the processing is likely to result in a risk to the rights and freedoms of data subjects, is not occasional, or includes special category or criminal offence data.
Source: GDPR, Art.30. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open GDPR in the compliance library.
Many articles apply only where their condition is met (a data protection officer under Article 37, an impact assessment under Article 35, a representative under Article 27); the condition is in each statement.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
- Version history showing when each entry was last reviewed and by whom · Document repository
periodic reviewEvidence produced at each review
- The record of processing activities in full, checked against the seven controller elements, or the four processor elements, the Article lists · Document repository
- Reconciliation of the record against a system inventory or data flow map, to show nothing is missing rather than that the entries read well · Data governance / DLP tooling
- Where the fewer than 250 persons exemption is claimed, the assessment against all three disqualifying conditions · Document repository
governing documentDocuments that govern the control
- The transfer entries with the third country identified and the safeguard documentation referenced · Document repository
First move
Common gaps auditors find
- Records written once during the implementation project and never updated against reality, so they describe systems long replaced and omit those adopted since
- Entries written at the level of a department or a system rather than a processing activity, which loses the purpose that everything else hangs off
- Erasure time limits left blank throughout on the where possible qualifier, while a retention schedule exists elsewhere in the organisation
- The small organisation exemption claimed on headcount alone, ignoring that regular non-occasional processing disqualifies it
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetArt.29 Processing under the authority of the controller or processor · Art.31 Cooperation with the supervisory authority