General Context

Already in the early 90’s, the European Union adopted the Data Protection Directive which regulated the processing of personal data within the European Union. The directive helped European citizens to be aware of their right to privacy, but the effect on the personal data itself was small. Partially because of the different interpretations of the directive by the individual member states.

With the General Data Protection Regulation (GDPR), a new and modernised law will become enforceable on the 25th of May 2018. The regulation wants organisations (companies, governments, NGO’s, …) to get a mindset of “Data protection by design”. And this not only for European organisations, but all organisations that handle personal data from a European citizen. Even if the organisation is located outside of the EU.

What is a Data Register?

With the WP-GDPR Core plugin and its add-ons, you have to tools at hand to process personal data and let your visitors manage that data themselves. We’re working on improving the process and explaining more on how the plugin works, so it will be easier for new users to get started with the WP-GDPR plugin. This will also help with changing the mindset of personal data.

Apart from managing personal data, it’s also very important to keep track of what happens to the personal data. Basically a history of all things related to the data. This includes:

• When did someone consent to storing the data?
• What data can we store and for how long?
• Who requested access?
• Who filed a delete request?

This “Record of processing activities” (Reference: Article 30 of GDPR) is often called the Data Register and must be available for consultation when privacy authorities ask for it. The Data Register let you keep track on who does what with personal data.

Data Register template

In many cases, creating a Data Register isn’t that hard and can be a good second step (First Step: Identifying all personal data) in getting GDPR compliant. To help you get a grip on the whole Data Register, we make a spreadsheet template available for you to download here:

https://docs.google.com/spreadsheets/d/1IsFLKF9kiZZ8Cp8fKrJkmhGODWy-Xkisa1MIzSHXHtw
(We’ve put the template in a Google Spreadsheet, so you can always access the latest version of it)

Automate all the things

As you can see, there’s some administration involved in keeping the Data Register up-to-date. In essence, the Data Register can be this spreadsheet on someone’s computer, but we suggest storing the Data Register on your website. This makes it possible to automate certain parts of storing. For example, we can store the consents from forms or the delete requests automatically in the Data Register of the WP-GDPR plugin.

Of course, since not every request or consent comes from the website, there should be an option to manually add records to the Data Register.
In future releases, we will try to make more integrations possible to automatically store the consent. We will start with the WP-GDPR Core and the add-ons.