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What Is ROPA & How to Maintain It

Understanding Records of Processing Activities (ROPA) and how to keep them updated and compliant.

Updated this week

Who this is for: Any organization that collects or processes personal data of individuals in the EU or UK.
Goal: Learn what a ROPA is, why it’s essential for GDPR compliance, and how to create and maintain one using Euverify.


1️⃣ What Is a ROPA?

ROPA stands for Record of Processing Activities.
It’s a structured record that explains how your business processes personal data — including what data you collect, why you collect it, who you share it with, where it’s stored, and how long you keep it.

Maintaining a ROPA is a legal requirement under Article 30 of the GDPR for nearly all organizations that process personal data on a regular basis.

It’s one of the key documents regulators will ask for first if they investigate your compliance.
A well-maintained ROPA shows accountability and transparency — two core GDPR principles.


2️⃣ Why Every Business Needs a ROPA

Even small or early-stage companies handle personal data daily — for example:

  • Website contact forms and newsletter signups

  • Customer orders and payments

  • HR or payroll information

  • Marketing analytics and email lists

Because these are regular processing activities, every organization must maintain a ROPA to document them.
Having this record helps you:

  • Demonstrate compliance during audits

  • Track what data you hold and where it’s stored

  • Identify unnecessary or risky data flows

  • Manage data subject access requests (DSARs) more easily


3️⃣ What a ROPA Should Contain

Each processing activity in your ROPA should include:

Section

What to Include

Activity Name

Example: “Customer Orders,” “Email Marketing,” “Employee Records.”

Purpose of Processing

Why you collect the data — e.g., order fulfilment, marketing, payroll.

Categories of Data

Types of data — e.g., name, email, IP address, bank details.

Data Subjects

Who the data belongs to — e.g., customers, employees, suppliers.

Recipients / Processors

Third parties you share data with — e.g., Shopify, Google, Stripe.

International Transfers

If data leaves the EU/UK, note where and what safeguards apply (e.g., SCCs).

Retention Period

How long you keep the data before deletion or anonymisation.

Security Measures

How you protect it — e.g., encryption, access control, secure backups.

Tip: Keep your language practical and specific. Avoid generic descriptions — focus on what actually happens in your business.


4️⃣ How to Build Your ROPA in Euverify

You can create or upload your ROPA directly within the GDPR Module.

Option 1 — Upload Your Existing ROPA

If you already have a ROPA document, simply upload it (accepted formats: PDF, DOC, XLSX, CSV).
It will be securely stored and accessible in your dashboard.

Option 2 — Use Euverify’s ROPA Builder

If you don’t yet have one, Euverify will guide you step-by-step through building it.

How it works:

  1. Open your GDPR dashboard → click Create New ROPA.

  2. Answer guided questions about your processing activities.

  3. The system automatically generates a structured, compliant ROPA.

  4. You can edit, add, or remove entries anytime.

Pro tip: Create one ROPA entry for each key activity — e.g., “Customer Orders,” “Email Marketing,” “Recruitment,” “CRM Management.”


5️⃣ How to Keep Your ROPA Up to Date

A ROPA should reflect your current data practices — not what you did months ago.
Whenever your business, systems, or partners change, your ROPA should change too.

Maintenance checklist

  • Review and update every quarter, or at least annually.

  • Add new vendors, processors, or marketing tools as soon as you use them.

  • Update retention periods and data flows if your policies change.

  • Remove outdated processes (e.g., discontinued campaigns).

  • Re-generate your ROPA file in Euverify after updates.

Example: If you start using HubSpot or switch from Mailchimp to Klaviyo, record that change immediately in your ROPA.


6️⃣ Why Maintaining Your ROPA Matters

Keeping your ROPA current:

  • Demonstrates compliance and accountability under GDPR.

  • Makes audits or regulator requests fast and stress-free.

  • Improves security awareness inside your team.

  • Simplifies data subject request handling.

  • Helps identify outdated or risky processes early.


7️⃣ Common Mistakes to Avoid

  • ❌ Treating the ROPA as a one-time document.

  • ❌ Forgetting to include vendors or cloud tools.

  • ❌ Using vague purposes like “for business operations.”

  • ❌ Leaving out retention periods.

  • ❌ Never reviewing after system or policy changes.

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