The Working Party 29 has examined the obligation for controllers and processors to maintain a record of processing activities, under Article 30 of the GDPR.
This paper sets out the WP29’s position on the derogation from this obligation.
It highlights that the record of processing activities is a very useful means to support an analysis of the implications of any processing whether existing or planned. The record facilitates the factual assessment of the risk of the processing activities performed by a controller or processor on individuals’ rights, and the identification and implementation of appropriate security measures to safeguard personal data – both key components of the principle of accountability contained in the GDPR”.
However, the WP29 recognises that Article 30 represents a new administrative requirement for controllers and processors, and therefore encourages national Supervisory Authorities to support SMEs by providing tools to facilitate the set up and management of records of processing activities.