Towards a Semantic Model of the GDPR Register of Processing Activities

Abstract: A core requirement for GDPR compliance is the maintenance of a register of processing activities (ROPA). Our analysis of six ROPA templates from EU data protection regulators shows the scope and granularity of a ROPA is subject to widely varying guidance in different jurisdictions. We present a consolidated data model based on common concepts and relationships across analysed templates. We then analyse the extent of using the Data Privacy Vocabulary - a vocabulary specification for GDPR. We show that the DPV currently does not provide sufficient concepts to represent the ROPA data model and propose an extension to fill this gap. This will enable creation of a pan-EU information management framework for interoperability between organisations and regulators for GDPR compliance.