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Overview

This article requires controllers and processors to maintain written records of all processing activities. Records must include information such as purposes of processing, categories of personal data, recipients, transfers, erasure timelines, and security measures. These records must be made available to supervisory authorities upon request, unless exempted for low-risk, small-scale processing.

Key Principles

• Accountability: Organizations must demonstrate compliance with GDPR by maintaining detailed records.

• Transparency: Records should clearly describe processing activities, including data categories, recipients, and transfers.

• Security and Retention: Include details on erasure timelines and technical/organizational measures.

• Exemptions: Small-scale or low-risk processing may be exempt from maintaining full records.
  
  

Organizational Applicability

This article applies to all organizations processing personal data within the EU:

• Controllers managing personal data of EU/EEA data subjects.

• Processors conducting data processing on behalf of controllers.

• Public and private sector entities required to demonstrate GDPR compliance.

• Teams responsible for record-keeping, compliance, IT systems, and data governance.
  
  

Implementation Requirements

• Maintain written or electronic records of processing activities.

• Include information on purposes, categories, recipients, data transfers, retention, and security measures.

• Ensure records are accessible to supervisory authorities upon request.

• Identify and document any exemptions applicable to small-scale or low-risk processing.
  
  

Implementation Guidance

• Use a centralized record-keeping system to capture all required information.

• Train staff to properly document and update processing activities.

• Periodically review records to ensure completeness, accuracy, and compliance.

• Implement access controls to protect records while ensuring availability for audits.
  
  

Periodic Review

• Frequency: Annually or when new processing activities are introduced.

• Responsible Role: Data Protection Officer (DPO) or Compliance Team.

• Outcome: Ensure records of processing activities are accurate, complete, and readily available to supervisory authorities.
  
  

Non-Compliance Risks

• Fines: Up to €20 million or 4% of global annual turnover.

• Legal Exposure: Regulatory investigations or enforcement actions for incomplete or missing records.

• Reputational Damage: Loss of trust from data subjects and authorities.

• Operational Risk: Inability to demonstrate compliance and respond effectively to audits or inquiries.