Phil, that's just what I was planning to do, but advice I had and the ICO example on their website seems to demonstrate that is not granular enough.
The ICO template for example has for purpose of processing "recruitment" by "HR" the example categories of personal data for "successful candidates" are shown as contact details, qualification details, employment history, ethnicity and Disability details. And then you go through the same listing of types of data for "unsuccessful candidates", and then for "personnel file" there is another list and so on across all business functions and processing activities.
For organisations with many different processing purposes and activities, trying to follow the template can make for an unwieldy document with potentially hundreds if not thousands of lines of data, especially if you go strictly by article 30 wording and you transfer data to other countries you appear to have to list each country individually for every processing activity.
A "system" that enables (and prompts) business functions to maintain and update their own records whilst providing a central sight of all business functions for governance functions starts to look attractive.
Chris
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 23 August 2018 15:47
To: [log in to unmask]
Subject: Re: [data-protection] Systems for complying with Art. 30
Do you need a system?
Start with your previous notification document, add a link to your (hopefully thorough) privacy notice(s), RM policy and retention schedule, IT security policy, and I think you have covered R30.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|