What is the difference between a RoPA and a data inventory?

A data inventory lists where personal data lives — which databases, object stores, SaaS applications and file shares hold it. A RoPA describes what you do with that data: the processing activity, its purpose, the lawful basis, the recipients and the retention period. The inventory is a map of locations; the RoPA is a record of conduct, and it is built on top of the inventory.

Dinkar Singh

The order matters. You cannot describe a processing activity accurately for data you have not found, which is why discovery comes first in any workable DPDP programme.

In practice organisations that skip the inventory end up with a RoPA describing the systems they remembered, which is a different set from the systems they operate.

General information about the DPDP Act, not legal advice. Obligations depend on your circumstances.

Dinkar SinghDinkar covers privacy engineering at ProtectComply — discovery, consent propagation and the evidence trail behind them.

Where do you stand under DPDP?

Take the free readiness check and find out in 10 minutes.

Start free readiness check →