What is a RoPA — and Why Every School Needs One Under Data Protection Requirements

May 28

EPS Ltd, covering the locations of:

ASEAN: Indonesia, Malaysia, Singapore, , Thailand, Vietnam.
EU/EEA and UK.

If your school handles student records, staff files, safeguarding notes, or parent contact details (and of course you do), then you’re legally responsible for how that personal data is managed.

That’s where your Record of Processing Activities — or RoPA — comes in.

What is a RoPA?

A RoPA (Record of Processing Activities) is an internal document. It is frequently required by law under many country’s Data Protection regulations, including ASEAN, EU/EEA and UK regions.

Think of it as your school’s data map. It shows:

What data you collect
Why you collect it
Who you share it with
How long you keep it
How you keep it safe

Why Is It Important?

Data Protection Regulations require all schools to be accountable — you must be able to show that you are handling personal data properly.

Your RoPA is one of the key ways to do this. It:

Helps you comply with the law
Supports your safeguarding and trust policies
Reduces the risk of data breaches
Shows the ICO (Information Commissioner’s Office) you’re on top of data protection

Is My School Required to Have a RoPA?

Yes — almost certainly.

Even in the EU and UK, though under GDPR organisations with fewer than 250 employees are sometimes exempt, schools are not, because:

You handle personal data regularly and systematically
You process sensitive (special category) data, such as health or safeguarding information

So yes — all state and independent schools must maintain a RoPA in wide international contexts.

What Should Be in a School's RoPA?

Each entry in your RoPA should cover:

Purpose of Processing: Attendance tracking, delivering education, safeguarding

Categories of Individuals: Pupils, staff, parents, governors

Categories of Data: Names, medical info, SEN status, behaviour logs

Who You Share Data With: Local authority, NHS, MIS provider, EdTech platforms

Retention Period: e.g. 6 years after leaving school

Security Measures: Passwords, access controls, encrypted storage

Who Creates and Maintains the RoPA?

Usually, the school’s Data Protection Officer (DPO) or a senior administrator maintains the RoPA. However, every team or department — from HR to SENCO — may need to provide details of how they handle data.

A GDPR consultant can also help review or build your RoPA to make sure it’s fit for purpose.

What Happens If We Don’t Have One?

It’s a breach of UK and EU GDPR and maybe a breach in some ASEAN nations.
You may be unable to respond properly to Subject Access Requests (SARs).
You may face scrutiny or enforcement action if the Data Protection Authority investigates your school after a breach or complaint.

Final Thought

Your school already does a lot to protect students and staff. A well-maintained RoPA simply puts that on paper — showing parents, staff, and regulators that you take data protection seriously.

It doesn’t have to be complex. But it does have to be accurate, up to date, and available on request.