Documenting Data Processing: Importance and Guidelines

Understanding Documentation Requirements

Factors Affecting Documentation: The need for formal documentation depends on organisational size, data volume, and type of data processed.

Comprehensive Recording: Documenting all processed data is essential for transparency and compliance.

Benefits of Data Inventory

Valuable Exercise: Despite not being mandatory for smaller organisations, creating a data inventory proves highly beneficial.

Identification of Processing: The inventory aids in identifying all processing activities and the corresponding data held.

Facilitating Policy Review: Helps significantly during privacy policy reviews by providing necessary compliance information.

Components of a Data Inventory

Inclusive Data: The content of a data inventory varies based on processing activities and data types.

• Data Source: Identify where the data originates, e.g., individuals or employers.
• Data Categories: Categorise the data subjects, such as employees, customers, or suppliers.
• Data Types: Specify the types of personal data processed, like contact information or financial records.
• Purpose of Processing: Define the purpose, such as supplying goods, payroll, or marketing.
• Lawful Basis: Document the legal basis for processing, whether contract, consent, or legitimate interest.
• Sensitive Data: Indicate if the data includes special category/sensitive personal data.
• Data Volume: Record the volume of data processed.
• Retention Period: Specify the duration for which the data is retained.
• Third-Party Recipients: List any third parties receiving the data.
• Data Transfer Safeguards: Ensure appropriate safeguards for data transfer.
• Individual Rights: Detail the rights available to individuals, such as access, rectification, or erasure.

Accessing an Example Inventory

An example data inventory template is available for download on the homepage.