It is important to understand and comply with the duty to keep records of processing activities, which are as follow:
Where we are the ‘Data Controller’
Each controller and, where applicable, shall maintain a record of processing activities under its responsibility.
That record shall contain all of the following information:
(a)the name and contact details of the controller and, where applicable, the joint controller, the controller’s representative and the data protection officer
(b) the purposes of the processing
(c) a description of the categories of data subjects and of the categories of personal data
(d) the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations
(e)where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and – where applicable – the documentation of suitable safeguards
(f) where possible, the envisaged time limits for erasure of the different categories of data
(g) where possible, a general description of the technical and organisational security measures used to protect the data
Where we act as ‘Data Processor’
Each processor shall maintain a record of all categories of processing activities carried out on behalf of a controller, containing:
(a) the name and contact details of the processor or processors and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s representative, and the data protection officer
(b) the categories of processing carried out on behalf of each controller
(c) where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and – where applicable – the documentation of suitable safeguards
(g) where possible, a general description of the technical and organisational security measures used to protect the data
The records referred to in paragraphs 1 and 2 shall be in writing, including in electronic form.
The controller or the processor and, where applicable, the controller’s or the processor’s representative, shall make the record available to the supervisory authority on request.
The obligations referred to in paragraphs 1 and 2 shall not apply to an organisation employing fewer than 250 persons unless:
- the processing it carries out is likely to result in a risk to the rights and freedoms of data subjects,
- the processing is not occasional, or
- the processing includes sensitive personal data or personal data relating to criminal convictions and offences