CIPP/E Study Guide
IAPP Training · Module 10 - BoK IV.B

Module 10 · Records of processing (Article 30)

Records of processing (Article 30) apply to organisations with 250+ employees, OR - regardless of size - where processing is likely to result in a risk, is not occasional, or includes special-category / criminal-conviction data, so they reach many small organisations too. Controller records and processor records overlap but differ: only the controller's records list the purposes of processing and the categories of data subjects and recipients.

  • Applies to organisations with 250+ employees, OR regardless of size where processing is likely to result in a risk, is not occasional, or includes special-category / criminal-conviction data.
  • Result: Article 30 reaches many small organisations too.
Controller records vs processor records (Article 30)
ElementController recordsProcessor records
Name/contact of the entity and DPOYes (controller + DPO)Yes (processor, controller + DPO)
Purposes of processingYesNo
Categories of data subjects, personal data and recipientsYesNo (instead: categories of processing for the controller)
Categories of processing carried out for the controllerNoYes
International transfers and safeguardsYesYes
Retention periodsYesNo
General description of security measuresYesYes
Burn-in distinction

The exam favourite: purposes of processing appear in the controller's records but NOT the processor's. International transfers and a general description of security measures appear in both.

Key terms - quick answers

What is “Records of processing”?
Article 30 written inventory of processing activities, kept by controllers and processors subject to thresholds.