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zsrrica-pixelzsrrica-pixel/gdpr-compliance-plugin/skills/ropa/SKILL.md

ropa

Skill1 starsChanged 41 days agoMITView on GitHub

Build or review a Record of Processing Activities (GDPR Art. 30). Use when the user wants to document processing activities, create a ROPA, or audit an existing one.

The file

Files
SKILL.md

Record of Processing Activities

For each processing activity capture: name and purpose; controller/joint controller/DPO contact; categories of data subjects; categories of personal data (flag special-category data); lawful basis (Art. 6, plus Art. 9 condition if relevant); recipients and processors; third-country transfers and safeguards; retention period; security measures (Art. 32).

Output as a table (or CSV if asked). When reviewing an existing record, list gaps: missing lawful basis, undefined retention, processors without DPAs, transfers without a mechanism. Ask the user about anything you cannot infer rather than guessing.

Handling unknowns and sources

  • Record the evidence source for each row (policy page, code, contract). Mark unknowns OPEN and collect them in an "Open questions" list at the end; in a non-interactive run, do not stop to ask.
  • Include one row per distinct purpose, including consent/cookie-driven processing (ads, pixels, analytics), payments, and rights handling. Mark inferred rows "inferred".
  • Finish with a "Gaps" list: processors without a DPA, transfers without a mechanism or TIA, missing lawful basis or retention, joint-controller questions (e.g. ad pixels), and anything that contradicts the privacy policy.

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