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What is a processing register and how do I build one?

A list per processing activity: what data, what purpose, how long, who shares it. Mandatory under GDPR Art. 30; the under-250-staff exemption falls away as soon as processing is structural or high-risk, which is essentially always the case for SMBs handling customer data.

Try this first

  1. 1Open a sheet or use the AP template. One row per processing: name, purpose, types of subjects, types of data.
  2. 2Add the retention period and the legal basis (consent, contract, legal duty, legitimate interest).
  3. 3List recipients per processing: HR tool, accounting, mail provider, external parties. Non-EEA countries separately.
  4. 4Describe the security measures at a high level: MFA, encryption, access control, backup.
  5. 5Review every six months or whenever a new tool comes in. The register need not be public but must be available on request to the AP.

When to bring us in

Processing special-category data (health, BSN, biometric) across multiple systems often needs a DPIA on top. Happy to scope it.

See also

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