RoPA management
When the DPC requests your Article 30 records, the last thing you want is a scramble
Most organisations maintain their RoPA in spreadsheets that drift from reality within weeks. New processing activities appear, vendors change, retention periods shift — and the register stays frozen. When the regulator asks, you're rebuilding from memory. Acompli turns approved DPIAs into draft RoPA entries with mandatory fields populated, confidence indicators attached, and cross-links to risks and source evidence — so your Article 30 records are always current.
Why teams rely on Acompli
RoPA that reflects your reality
Automatic drafts, relationship mapping and export-ready registers mean your Article 30 obligations become an integrated habit.
1. Readiness check
Acompli verifies that the DPIA captured the information regulators expect before drafting starts, highlighting any gaps so reviewers can close them in moments.
Quality predictions surface early, keeping downstream corrections to a minimum.
2. Structured extraction
AI drafts every Article 30 field – from purposes and lawful bases to retention periods and safeguards – complete with confidence scores and reasoning so reviewers know where to focus.
Each entry links back to the source assessment, giving instant context when questions arise.
3. Consistency analysis
Cross-record validation catches duplicates, conflicting dependencies and outdated relationships, prompting reviewers before publication.
Published records remain aligned with the latest DPIA and risk updates, making exports defensible on demand.
How RoPA stays current in Acompli
Simplify updates by weaving record management into everyday work.
- Approve the DPIA – structured answers capture the full picture of the processing activity.
- Verify readiness – readiness checks confirm critical inputs before drafting begins.
- Review the draft entry – Acompli proposes lawful bases, data subjects, categories and recipients with confidence scoring.
- Link dependencies – connect related systems, vendors, risks and mitigation plans for a complete view.
- Publish and monitor – scheduled reviews prompt you when an activity needs attention.
- Export anytime – produce regulator-ready reports in your preferred format.
What this means for you
- Confidence – Article 30 requests become routine, not a scramble.
- Alignment – risks, DPIAs and RoPA entries reference each other with shared evidence and confidence levels.
- Visibility – stakeholders see a single, living record of processing activities.
- Scalability – new activities adopt the same structure consistently, without extra admin.
GDPR Article 30 RoPA Requirements: Complete Compliance Checklist
Article 30 of the GDPR mandates that controllers and processors maintain detailed records of processing activities. Understanding these requirements is essential for compliance and demonstrating accountability to supervisory authorities.
Mandatory Fields for Controllers (Article 30(1))
Controllers must document the following for each processing activity:
- Name and contact details of the controller, joint controllers, controller's representative, and Data Protection Officer (where applicable)
- Purposes of processing — why personal data is being collected and used
- Categories of data subjects — customers, employees, suppliers, website visitors, etc.
- Categories of personal data — identifiers, financial data, location data, special category data
- Categories of recipients — internal departments, third-party processors, public authorities
- International transfers — documentation of transfers to third countries or international organisations, including transfer mechanisms (SCCs, adequacy decisions, BCRs)
- Retention periods — time limits for erasure or review, linked to legal obligations or legitimate purposes
- Technical and organisational measures — security safeguards under Article 32 (encryption, access controls, pseudonymisation)
Mandatory Fields for Processors (Article 30(2))
Processors must maintain records containing:
- Name and contact details of the processor, controller(s) on behalf of whom processing occurs, processor's representative, and DPO
- Categories of processing carried out on behalf of each controller
- International transfers with documentation of transfer mechanisms and safeguards
- Technical and organisational measures for security of processing (Article 32)
Small Organisation Exemption (Article 30(5))
Organisations with fewer than 250 employees are exempt unless:
- Processing is likely to result in a risk to the rights and freedoms of data subjects
- Processing is not occasional (regular, ongoing activities require records)
- Processing includes special categories of personal data (Article 9) or criminal conviction data (Article 10)
In practice, most organisations fall outside the exemption because they process personal data regularly. Supervisory authorities expect records even from small businesses handling customer, employee, or marketing data.
RoPA Best Practices for Accuracy and Maintainability
Granularity: Finding the Right Level of Detail
One of the most common RoPA failures is choosing the wrong level of granularity. Recording "HR data" as a single entry provides no meaningful insight for risk assessment or breach response. Recording every individual employee's data creates an unmanageable register.
The correct unit is the processing activity: a distinct business process with a clear purpose, data set, and lifecycle. Examples include:
- Recruitment candidate screening and selection
- Employee payroll administration
- Customer email marketing campaigns
- Website analytics and behaviour tracking
- Third-party payment processing for e-commerce transactions
Each activity should be specific enough to identify risks and accountable owners, but broad enough to remain maintainable as systems and teams evolve.
Common RoPA Maintenance Challenges
- Static snapshots: RoPAs become outdated as soon as systems change, vendors are replaced, or retention policies shift.
- Inconsistent terminology: Different teams describe the same processing activities in different ways, creating duplicate entries or gaps.
- Lack of ownership: No clear accountability for keeping entries current leads to drift and inaccuracy.
- Disconnected from operations: RoPA updates lag behind actual processing changes because they are manual, annual exercises rather than integrated into project workflows.
- No link to source evidence: When auditors or regulators ask "How did you determine this retention period?", there is no traceability back to the DPIA or policy that justified it.
Article 30 RoPA Compliance FAQs
What is a RoPA and why is it required?
A Record of Processing Activities (RoPA) is a comprehensive inventory of how an organisation processes personal data, mandated by GDPR Article 30. It serves as the foundational accountability document, demonstrating to supervisory authorities that the organisation understands its data estate, has assessed risks, and implements appropriate safeguards. The RoPA is often the first document requested during audits or breach investigations.
Do small businesses need a RoPA?
Article 30(5) provides a limited exemption for organisations with fewer than 250 employees, but this exemption does not apply if processing is likely to result in risk to individuals, is not occasional, or involves special categories of data. In practice, most businesses—regardless of size—process customer, employee, or marketing data regularly and therefore require a RoPA. The ICO and DPC expect small businesses handling personal data to maintain at least basic processing records.
What's the difference between a RoPA and a DPIA?
A RoPA (Article 30) is a high-level register of all processing activities across the organisation. A DPIA (Article 35) is a detailed risk assessment for specific high-risk processing activities. Think of the RoPA as the map of your entire data estate, and DPIAs as deep dives into areas where risks require thorough analysis. Acompli generates draft RoPA entries from approved DPIAs for review, ensuring consistency and reducing duplication of effort.
How often should a RoPA be updated?
The GDPR does not prescribe a specific review cycle, but supervisory authorities expect RoPAs to be current and accurate at all times. Best practice is to update the RoPA whenever processing activities change—new systems, new vendors, new data categories, changes to retention periods, or new international transfers. Acompli's approach ties RoPA updates to DPIA approvals, ensuring the register reflects operational reality as projects are completed and reviewed.
What format should a RoPA be in?
GDPR does not mandate a specific format. RoPAs can be spreadsheets, databases, GRC platforms, or dedicated compliance tools. However, the format must support the required fields under Article 30, allow for updates and version control, and be producible to supervisory authorities on request. Acompli provides structured RoPA management with automated field extraction, confidence scoring, and regulator-ready export formats (PDF, Excel, JSON).
Can Acompli generate RoPA entries automatically?
Yes. When a DPIA is approved in Acompli, the platform analyses the assessment content and drafts a complete RoPA entry with all Article 30 fields populated—purposes, legal bases, data categories, recipients, retention periods, safeguards, and international transfers. Each field includes confidence scoring and links back to the source DPIA response. Human reviewers approve or adjust the draft before publication, ensuring accuracy and accountability while dramatically reducing manual work.
RoPA management is included in every Acompli plan
No separate Article 30 tool subscription. Readiness checks, structured extraction, consistency analysis, dependency mapping and regulator-ready exports — all connected to your DPIAs, risk register and data map in one platform. From €149/seat/mo at the founding rate.