RoPA: The 8 Statutory Fields, Not Auto-Generated

Duration and the minimum bar

The Record of Processing Activities is kept throughout the processing period, plus 5 more years after it ends. The law sets 8 statutory minimum fields, so a generic entry like "we process customer data" doesn’t meet that bar.

Why it can’t be fully auto-generated

An automated scan finds where the data is and what type it is. But the purpose of processing, the legal basis, and which unit owns it inside each department are context the department itself holds, not something a discovery engine can infer on its own. A correct record is genuinely a mix: the scan builds the structure, and departments fill in what’s missing.