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SecuriFii

Evidence

Records of processing: the artefact every privacy obligation leans on

It looks like paperwork and it is infrastructure. Nearly every privacy obligation resolves to a question this record answers.

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What must a record of processing contain?

What personal data you hold, the purposes it is processed for, the categories of data subject, who it is shared with including sub-processors, any transfers outside the country, retention periods, and a description of the security measures applied.

The work is rarely the document — it is the discovery. Personal data accumulates in support tools, analytics, log files, spreadsheets and backups, and the first honest inventory is usually a surprise. That is exactly why it precedes the notice, the consent mechanics and the rights process, all of which depend on knowing what you actually hold.

The bottom line

Do the mapping first. Every downstream privacy decision depends on it, and every one of them is wrong if it is wrong.

  • ISO/IEC 27701 — Privacy Information Management

    Turn privacy from a policy document into a management system, with the records a regulator or an enterprise buyer will ask to see.

  • GDPR Compliance

    Work out whether the GDPR reaches you directly or by contract, then build the records, processes and transfer answers either route demands.

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