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Records of processing activities: what to include, with an AI tool example

Who must keep a record of processing activities, which fields it needs and what an AI assistant entry looks like, with a worked fictional example.

In brief

  • A record of processing activities lists all processing of personal data in your organisation, with a fixed set of information for each activity.
  • The exemption for organisations employing fewer than 250 people rarely applies in practice, because almost no processing is occasional.
  • The law specifies seven components for controllers and four for processors; you choose the format.
  • An AI tool able to access documents containing personal data requires its own entry and often affects existing entries too.
  • The record is not a one-off document: every new tool, supplier or retention period means a change.

What is a record of processing activities and what must it contain?

A record of processing activities is the written overview of all personal data processing for which your organisation is responsible. For each activity, record who is responsible, why you use the data, whom it concerns, what types of data are involved, who receives it, whether it leaves the EU, how long you retain it and how you protect it.

The GDPR calls it a “record of processing activities”. The obligation is in Article 30 GDPR. It is an internal document, different from your public privacy statement, that demonstrates you know what you do with personal data. The Autoriteit Persoonsgegevens (AP), the Dutch data protection authority, includes it among the mandatory accountability measures, alongside the DPIA, data breach register and privacy statement, among others.

Who must keep a record of processing activities?

Under Article 30(1), every controller keeps a record of processing carried out under its responsibility. Paragraph 2 imposes a similar obligation on processors. The exemption is in paragraph 5.

The paragraph 5 exemption as written in law

Paragraph 5 says the obligations do not apply to enterprises or organisations employing fewer than 250 people. This is followed by an “unless” covering three situations:

If any one applies, even a small organisation must keep a record.

Why the exemption hardly ever applies

The AP writes that processing is rarely occasional in practice, giving the examples of data about your own employees, customers, clients, patients or residents. Anyone with staff or regular clients therefore almost always has a record-keeping obligation. Asked by a small healthcare practice whether a record is required, the AP answers: yes, usually.

A proposal to change the threshold

The European Commission has proposed amending paragraph 5. According to the EDPB and EDPS announcement of their joint opinion of 9 July 2025, the exemption would then apply to organisations with fewer than 750 employees, unless processing is likely to involve high risk. On 13 October 2026, we found no adopted text of that amendment. Until then, Article 30 applies as described above. Check the status before basing a decision on it.

Which fields does a controller's record have?

Article 30(1) lists seven components, from (a) to (g). The table below places them alongside what you enter and an example for an AI tool. The example is fictional.

What “where possible” means

The words “where possible” apply only to retention periods and security. They are not a free pass to leave those fields blank. If you do not yet know the retention period, write down how you will determine it and when.

What the law does not require, but helps

Article 30 does not mention the lawful basis for processing. Many organisations still include it, along with the processor's name, a reference to the data processing agreement and whether a DPIA has been done. That is a choice. The AP says you may decide how to draw up the record, provided it contains the prescribed information. Under paragraph 3, it must be in writing, including electronically. A spreadsheet meets that format requirement.

What is in a processor's record?

If you process data on another party's behalf, for example as a bookkeeping firm or online service provider, paragraph 2 requires your own record. It is shorter, with four components.

Many organisations are both: controller for their own personnel administration and processor for a client. The record then has two parts. For agreements with an AI tool provider, see the article about a data processing agreement with an AI provider.

What does the Autoriteit Persoonsgegevens say about the record?

The AP's accountability page explains who must keep a record and what it contains. Three points matter in practice.

The supervisory authority may request it

Under Article 30(4), you make the record available to the supervisory authority on request. You do not need to submit or publish it. You must be able to show it when the AP asks. Starting to create one only after such a request is too late.

The organisation maintains it, not the DPO

According to the AP, the processing overview is the organisation's own responsibility and not a task for the data protection officer. The DPO supervises it. In practice, DPOs do often keep a list, particularly of risky processing. Who is responsible for what within an organisation is explained in the article about AI governance.

For generative AI, the AP starts with the record

In July 2026, the AP published a tool for deploying generative AI, together with its advice on Microsoft 365 Copilot at a municipality. The tool's first component is the record of processing activities. The AP recommends checking and, where necessary, updating the record before deploying generative AI, and using it to assess which existing processing activities are affected. The advice says the record must at least show broadly which processing activities a generative AI system affects, and that an organisation using such a system must in any event have a record, especially if it can access files containing personal data.

Does an AI tool belong in the record of processing activities?

Yes, as soon as personal data enters it: a name in a question, an email you have rewritten, a client file you upload. The record describes processing, not software. Nevertheless, an AI tool almost always prompts changes to the record in two ways.

A new entry for the new use

Using an AI assistant to search client files is a separate processing activity with its own purpose, recipients and often retention period. It gets its own entry. A worked example follows below.

Updating existing entries

The AP points out that generative AI generally brings new processing and can change how existing processing is performed. Giving an assistant access to your document environment affects personnel, client file and complaint entries at once. Each entry's list of recipients changes, and sometimes its transfers too.

What you do not see is absent

A record can describe only what the organisation knows. If employees use a personal account, that processing is recorded nowhere. This is covered in the article about shadow AI. Which plans have a data processing agreement is explained in the plan comparison.

Example record: an entry for an AI assistant

This example is fictional. Voorbeeldkantoor Noord is a fictional consultancy with forty employees using an AI assistant to search closed and ongoing client files.

The periods and dates in this example are fictional. Never enter a retention period you have not seen in your own plan's terms or settings.

What stands out in this example

The entry is specific: it also states what does not go in, and everything that may change has a date. Whether health data belongs in such a tool is a separate question to answer first. See the article about special category data.

How do you keep the record up to date?

The AP writes in its advice that the record achieves its purpose only if complete and regularly updated. A fixed rhythm works better than good intentions.

  1. Appoint an owner. One person manages the document. Each entry names whoever carries out the processing.
  2. Connect it to purchasing. No new tool or plan without someone asking whether the record changes.
  3. Review suppliers. Each quarter, check your AI provider's sub-processor list and retention periods and add a reference date.
  4. Compare it with the DPIA. High-risk processing has both. For what an AI tool DPIA contains, see the article about DPIAs.
  5. Compare it with the policy. If your AI policy lists a tool as permitted, there should be an entry. See Creating an AI policy.

Common mistakes

Public authorities also have a separate instrument for algorithms. It differs from the processing record and is explained in the article about the Dutch Algorithm Register and IAMA.

What PrivaSearch does here

PrivaSearch pseudonymises personal data in documents before an AI assistant searches them. That processing itself also belongs in your record. Your PrivaSearch environment therefore creates a register entry for this one activity: purpose, data subjects, data categories, recipients, transfers, retention period and measures. The entry is intended to be pasted into your own record.

The entry comes from one form, alongside three other documents: an AI policy, a DPIA starter document and a written lawful basis with balancing assessment. They are prepared deterministically, without a language model. The contents follow your environment's configuration, so no measure appears unless enabled. For these documents and their contents, see the page about the GDPR and the EU AI Act.

These are starter documents, not legal advice. The rest of your record, your data protection officer's advice and formal adoption remain your responsibility. PrivaSearch therefore pre-fills one entry, not your whole record.

What the entry says about recipients and transfers depends on what you connect. Pseudonymisation and mandatory review are explained on the page about how it works. What a connected assistant does and does not see is on the page about AI chatbots and the GDPR. Parties involved in processing are in the sub-processor overview. Pseudonymised data remains personal data for your organisation, so the entry remains necessary. To see the register entry, book a demo.

Frequently asked questions

Is a record of processing activities mandatory for a small business?

Usually. The exemption for organisations employing fewer than 250 people ceases to apply if processing is not occasional, poses a risk to data subjects or involves special category or criminal offence data. Personnel administration or a client database is not occasional. The Autoriteit Persoonsgegevens writes that processing is rarely occasional in practice. Anyone with staff or regular clients therefore almost always keeps a record.

What must a record of processing activities contain?

For controllers, there are seven components: name and contact details, processing purposes, categories of data subjects and personal data, categories of recipients, transfers to countries outside the EEA, retention periods and a general security description. The last two say “where possible”. A processor keeps a shorter record with four components.

Where can I find an example processing record for AI tools?

This article includes a fictional entry for an AI assistant searching client files, with all seven statutory fields and some optional ones. Use the structure and enter your own details. Retention periods, recipients and transfers vary by provider and plan. Take them from your own contract and settings, with a reference date.

Must I send the record to the Autoriteit Persoonsgegevens?

No. You do not need to submit or publish it. You must be able to make it available when the supervisory authority asks. It must therefore exist, in written or electronic form, and be up to date when requested.

Who maintains the record: the DPO or the organisation?

The organisation. According to the Autoriteit Persoonsgegevens, the processing overview is the organisation's own responsibility, not a data protection officer's task. The DPO supervises the record and can advise. In practice, a privacy officer or operations employee often manages the document, with an owner for each entry from the department carrying out the processing.

How often must you update a record of processing activities?

The law specifies no interval. The record must reflect what you do, so every new processing activity, tool, supplier or retention period means a change. In practice, a regular check works, for example quarterly for entries involving an external supplier and annually for the rest. AI tool terms and sub-processors change regularly, so add a reference date to those entries.

Read more

  1. The AI Act in autumn 2026: what applies now and what has been postponed?

    The AI Act timeline after the digital omnibus: what applies already, what has moved to 2027 and 2028, and what AI chatbot users need to arrange now.

  2. Deepfakes and the law: what the AI Act and GDPR do about them

    What a deepfake is, which rules apply now, which prohibition is coming and how organisations tackle fraud using a fabricated voice or video.

  3. The Algorithm Register and IAMA: what public bodies must record about their AI

    What the Dutch Algorithm Register and IAMA are, what is mandatory and what is not, and what a municipality arranges when staff use AI chatbots.

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