One register for everything you do with personal data. Checked against your code.

Your code shows part of the picture. Payroll, CCTV, the call centre and the paper forms at reception never touch a repository. The Processing Register keeps all of it in one record of processing, asks the people who run each process for their part, and checks the part code can prove against the code.

Code + peopleTwo sources, one register
DPDPA · GDPR Art. 30Records in both layouts
GapsEach one cites its provision
01 · Two sourcesONE RECORD

What the code shows, and what only people know.

Activities that run through your applications are seeded from the scans: the personal data, the systems that store it and the third parties it reaches. Everything else comes in from a sheet you already have, or from a questionnaire. Each row says where it came from, so nobody has to guess which parts were checked and which were stated.

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A register of six processing activities for NorthBay Health: call centre bookings, CCTV, the patient portal, recruitment, payroll and paper registration, each with a status, legal basis, source (code or import) and next review date.
The patient portal row came from the code scan. Payroll, CCTV and the paper forms at reception came from an imported sheet.
02 · Ask the person who knows

A link to the HR lead, not a workshop.

Send a questionnaire to the owner of each process: HR, the front office, facilities, a vendor. They answer from a link, with no account, and the answers save as they go. Reminders go out before the due date. You review the answers and commit them, and they become rows of the register.

Questionnaires for general processing, HR, healthcare, financial services, e-commerce and education, for systems and vendors, and for impact assessments. Or turn your own Word or Excel questionnaire into one.

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An HR and employment processing questionnaire sent to Priya Nair at NorthBay Health, due on 4 November, with the first questions about the activity and its owner.
What the respondent sees. It warns them not to type anyone's personal details into an answer.
03 · Checked against codeRECONCILIATION

When the interview and the code disagree, you see it.

A flow the code shows but nobody declared is marked code only, for a decision: adopt it into the record or explain it. A flow declared in an interview that the code never shows is marked too. Each new scan runs the comparison again, and a flow that stops appearing in the code is marked stale rather than quietly kept.

Here the patient portal sends a patient's photo, licence number, name and phone to an identity check vendor. Nobody listed that vendor in an interview. The code did.

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Flows of the patient portal activity: from the patient portal API to VisionAI, carrying government identifiers, biometric data and identity details, each sourced from code and marked code only.
04 · Gaps

What is missing, and the provision that asks for it.

Rules run over the register itself: a recipient with no processing agreement, sensitive data with no encryption recorded, no retention rule, no lawful basis. Each finding names the provision and what to do, and goes away when the row it points at is fixed. Activities that need an impact assessment are flagged, and the assessment runs as a questionnaire with sign-off.

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Gaps for NorthBay Health: 23 findings across 6 activities, such as Exotel receiving call centre data with no processing agreement recorded (DPDPA s.8(2)) and health data with no encryption at rest recorded (DPDPA Rule 6).
05 · The recordEXPORTS

Something you can hand over.

Export the record of processing in the DPDPA layout or the GDPR Article 30 layout, as a spreadsheet, a PDF or JSON, with the list of sub-processors and the data-flow diagram. Every version is kept, so you can show what changed between two reviews. Consultants can put their own name on the exports and hand the whole engagement over as one bundle.

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Where personal data goes at NorthBay Health: biometric data, contact details, government identifiers and identity details flowing to the patient portal and to VisionAI, drawn in red because they are unprotected.
The same diagram the code scans draw, built from the register.
06 · A programme, not a project

It stays true after the first sign-off.

REVIEWS ON A CYCLE

Each activity has a review date. When it comes due, the owner is asked to confirm it still holds, and their answer is kept as an attestation.

CHANGES ARE REQUESTED

Anyone can propose a change to an activity. It is reviewed and decided, not edited in place, so the history shows who changed what and why.

VENDORS HAVE A LIFE

Processing agreements with their dates, a risk tier, a review cadence and an assessment you can send. A vendor being offboarded is visible as such.

Talk to us about the registerKeeping a RoPA currentConsent Capture