Task 1 — Identify Processing Activities

Ask every department one question: what do you do with personal data?

A processing activity is a business process that uses personal data for one purpose, such as payroll, recruitment or the newsletter. Short interviews with the process owners find them faster than any questionnaire.

How to find them

  • HR: recruitment, payroll, time recording, personnel files, training
  • Sales and marketing: customer management, newsletters, events, website and analytics
  • Finance: accounting, invoicing, debt collection
  • IT: user accounts, logging, e-mail, video surveillance and access control
  • Core business: the processes that are specific to your organisation
  • Rule of thumb: one entry per purpose. "HR" is too broad, "payroll" and "recruitment" are two activities.

Records requirement in your jurisdiction

Mexico

The LFPDPPP does not require a GDPR-style record, but the security measures include an inventory of personal data and processing systems, and the privacy notice and ARCO procedures rely on knowing every processing activity.

Example: result of a 30-minute interview with HR

Processing activityPurpose in one sentenceProcess owner
RecruitmentSelect applicants for open positionsHead of HR
PayrollPay salaries and meet tax and social security obligationsPayroll officer
Time recordingRecord working hours and absencesHead of HR
Personnel filesManage the employment relationshipHead of HR
TrainingPlan and document employee trainingHR development

In ResGuard, create one entry per activity in the Data Inventory (RoPA) right after the interview; the details follow in the next tasks.