List of Data Processing Activities

This template is supposed to give you an idea of the structure. Don’t use word – this is thought as an excel / sheets file. Think of the sub-sections below as different tabs in your excel sheet.

Disclaimer: data privacy documentation should usually be written in the official language of your EU member state. Most likely, you should translate this template accordingly. In German, people refer to this typically as the ‘Verzeichnis der Verarbeitungstätigkeiten’…

Data Processing Activities

Note that this tab should exist twice: one time for internal processing activities and one time for external ones. Internal processing refers to your internal data that third parties may process on your behalf (for example: your tax accountant, your cloud provider, providers of all the tools you use in your company). External processing refers to data of third parties that you process on their behalf (for example: customer data that is transferred to your servers to be analyzed by your brand-new AI algorithm).

Categories: ID – Controller – Controller Address – Controller Contact Details – Legal Basis – Processing Purpose – Category of Data – Data Subjects – Start Date of Processing – End Date of Processing – Processor – Processor Address – Processor Contact Details – Legal Basis – Threshold Analysis – DPIA – Description of TOMs – Deletion Period – Transfer to Third Countries – Safeguards – Commentary

Consider that you will have a ton more data processing activities than categories. Write your categories as columns and processing activities as rows (the table in this template is transposed (rows and columns flipped) due to formatting reasons).

Categories	Data Processing Example #1: Processing of Health Data by a Cloud Provider (Internal)	Data Processing Example #2: Processing of Applicant Data by a Software Tool Provider (Internal)	Data Processing Example #3: Processing of Health Data by Your Company as Clinical Decision-Support (External)	(…)
ID	1	2	3
Controller	Example GmbH	Example GmbH	Berlin-Based Example Customer
Controller Address	Example Street 123 10000 Berlin Germany	Example Street 123 10000 Berlin Germany	(…)
Controller Contact Details	John Doe [email protected]	John Doe [email protected]	(…)
Legal Basis	Commissioned Data Processing (Art. 6 Sect. 1 lit. b) GDPR)	Pre-Contractual Measures (Art. 6 Sect. 1 lit. b) GDPR)	Commissioned Data Processing (Art. 6 Sect. 1 lit. b) GDPR)
Processing Purpose	Provision of Cloud Services	Management of Applicant Data	Provision of Decision-Support for Clinical Diagnoses
Category of Data	Patient Data (e.g. DICOM image data and clinical information)	Applicant Data (e.g. CV, cover letter, reference documents)	Patient Data (e.g. DICOM image data and clinical information)
Data Subjects	Patients that undergo CT lung cancer screening	Applicants to Example GmbH	Patients that undergo CT lung cancer screening
Start Date of Processing	01.08.2021	01.01.2021	01.08.2021
End Date of Processing	N/A	N/A	N/A
Processor	Berlin-Based Example Cloud Provider	California-Based Example Software Provider	Example GmbH
Processor Address	(…)	(…)	Example Street 123 10000 Berlin Germany
Processor Contact Details	(…)	(…)	John Doe [email protected]
Legal Basis	Commissioned Data Processing (Art. 6 Sect. 1 lit. b) GDPR)	Commissioned Data Processing (Art. 6 Sect. 1 lit. b) GDPR)	Commissioned Data Processing (Art. 6 Sect. 1 lit. b) GDPR)
Threshold Analysis	Acceptable	Acceptable	N/A
DPIA	N/A	N/A	N/A
Description of TOMs	Entry Control: locked building, documented key assignment (..) Access Control: central password authentication incl. 2FA (…) Usage Control: role-based authorization (…) Availability: uninterrupted power supply, continuous backups (…) (…)	(…)	(…)
Deletion Period	30 days after data ingestion	6 months	30 days after data ingestion
Transfer to Third Countries	No	United States of America (USA)	No
Safeguards	N/A	EU Model Contract Clauses	N/A
Comment		Note that after ECJ Schrems II ruling, model contract clauses alone are not sufficient to safeguard data transfer to the U.S.

Threshold Analysis and Data Protection Impact Assessment

Note that it is the responsibility of the controller to carry out a DPIA (Art. 35 GDPR)

Optionally, you can split this section into two separate tabs.

Reasoning: whenever a risk is deemed acceptable in a previous section, the documentation ends right there. For example, if the overall severity and probability of a risk are deemed acceptable, you don’t have to dive into further evaluation criteria of the next section or let alone start the DPIA for this risk. Sections are shown in the text below in brackets – use different formatting when you adopt this template).

As part of your DPIA, you typically analyze several risk causes. More risk examples are listed in the risk methodology section.

Categories TA: (Risk Identification) – Processor – Processing Purpose – Risk Cause – Risk Description – (Initial Risk Assessment) – Severity – Probability – Assessment – (Further Evaluation Criteria: Special Processing) – Processing large quantities of personal data – Processing affects a large number of people – Use of new technologies – Processing hampers the exertion of data subject rights – Processing hampers the use of services or exertion of contracts for data subjects – Processing of data of vulnerable persons – (Further Evaluation Criteria: Automated Decision-Making) – By systematic assessment of personal characteristics based on profiling – By processing special categories of personal data – (Responsible data protection authority deemed processing high-risk)

Categories DPIA: Planned additional measures – (Re-Evaluation) – Severity after measures – Probability after measures – New assessment – (Implementation) – Responsible – Status – Date of Implementation – Notification of Authorities

Categories	Data Processing Example #1: Processing of Health Data by a Cloud Provider (Internal)	Data Processing Example #2: Processing of Applicant Data by a Software Tool Provider (Internal)	(…)
Threshold Analysis	–	–	–
Risk Identification	–	–	–
Processor	Berlin-Based Example Cloud Provider	California-Based Example Software Provider
Processing Purpose	Provision of Cloud Services	Management of Applicant Data
Risk Cause	Unauthorized access	Unauthorized access
Risk Description	Sensitive patient data could be identified by third-parties, leading to a risk of identity theft	Applicant data could be identified by third-parties, leading to a risk of identity theft
Initial Risk Assessment	–	–	–
Severity	S4	S3
Probability	P2	P2
Assessment	Unacceptable	Acceptable
Further Criteria: Special Processing	–	–	–
Processing large quantities of personal data	No	–
Processing affects large numbers of people	No	–
Use of new technologies	No	–
Processing hampers the exertion of data subject rights	No	–
Processing hampers the use of services or exertion of contracts for data subjects	No	–
Processing of data of vulnerable persons	No	–
Further Criteria: Automated Decision-Making (ADM)	–	–	–
ADM by systematic assessment of personal characteristics based on profiling	No	–
ADM by processing special categories of personal data	No	–
Responsible Data Protection Authority deems processing high-risk	No	–
Data Protection Impact Assessment	–	–	–
Planned additional measures	–	–
Re-Evaluation	–	–	–
Severity after measures	–	–
Probability after measures	–	–
New assessment after measures	–	–
Implementation	–	–	–
Responsible Role	–	–
Status of Implementation	–	–
Date of Implementation	–	–
Notification to Authorities	–	–
Comment

Risk Methodology

This field should provide the taxonomy and an overview of the possible categories of content entered in the previous tabs.

Possible categories of risk:

• Data loss (availability)
• Unauthorized access (confidentiality)
• Unauthorized modification (integrity)
• Non-compliance (e.g. not deleting data)

Categories of data processed by the company:

• Employee data
• Customer data (of commercial partners)
• User data (of employees of partners)
• Patient data

Degree of Severity	Social Damage (e.g. discrimination, loss of reputation)	Financial Damage	Identity theft	Mortal Danger	Disclosure of Secrets
S1: Low	No or minor societal or economical disadvantages in daily life	In the scope of a one month salary
S2: Rather Low	Societal or economical disadvantages can be noticed and lead to minor restrictions in daily life	In the scope of several months of salary
S3: Rather high	Implications for an entire part of daily life for a person affected (e.g. work place / professional environment)	In the scope an annual salary			Disclosure of secrets has implications for a part of life of a person affected
S4: High	Major disadvantages for an affected person across all fields of life (e.g. job loss or implications for personal surrounding)	Loss of all financial means	Identity theft	Mortal danger	Geheimnisoffenbarung hat Auswirkungen auf das gesamte Leben des Betroffenen.

Probability of Occurrence	Future Estimate	Past Estimate
P1: Never	Event is unimaginable	Event has never occurred
P2: Seldom	Event may on average occur once every 10 years	Event has never occurred or more than 10 years ago
P3: Rather unlikely	Event may on average occur every 5-10 years	Event has occurred in the last 5-10 years
P4: Rather likely	Event may on average occur every 1-5 years	Event has occurred in the last 1-5 years
P5: Frequently	Event occurs at least once per year	Event has occurred in the last year

Note: fields that are marked red symbolize a combined severity and probability that is unacceptable, yellow fields are acceptable.

	S1: Low	S2: Rather Low	S3: Rather High	S4: High
P5: Frequently	S1P5 (yellow)	S2P5 (red)	S3P5 (red)	S4P5 (red)
P4: Rather likely	S1P4 (yellow	S2P4 (red)	S3P4 (red)	S4P4 (red)
P3: Rather unlikely	S1P3 (yellow)	S2P3 (yellow)	S3P3 (red)	S3P3 (red)
P2: Seldom	S1P2 (yellow)	S2P2 (yellow)	S3P2 (yellow)	S4P2 (red)
P1: Never	S1P1 (yellow)	S2P1 (yellow)	S3P1 (yellow)	S4P1 (yellow)

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