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Records of processing

Also known as: record of processing activities · ROPA · processing inventory

Records of processing are the documented inventory of what an organization does with personal information: which data, for which purposes, kept how long, shared with whom.

It is the first document a regulator asks for, because it immediately reveals whether the organization knows what it processes. A company that cannot produce it cannot demonstrate any of the other principles.

It does not need to be a tool: a maintained spreadsheet is enough, provided it genuinely covers the processing and not only what someone remembers.

Building it has a useful side effect: filling it in is how most organizations discover flows they had forgotten, especially into tools a team adopted without going through management.

What it means for a small business

An hour spent honestly listing your tools and what each one receives produces more real compliance than a ten-page privacy policy copied from elsewhere.

The evidence registry

So what actually applies to you?

A definition tells you what a term means, not what your organization must do. The assessment answers the second question — free, no credit card.

Updated September 1, 2026 · Educational definition; not legal advice.