The future of RoPAs in an AI-powered world

In an article for IAPP, contributor Roy Kamp writes that traditional spreadsheet-based Records of Processing Activities (RoPAs) are outdated, hindering innovation, scalability, and brand protection. Today's artificial intelligence (AI) era demands a fundamental shift from a retrospective process that relies on interviews and manual data mapping, leading to incomplete and quickly outdated information. 

Instead, Kamp argues that the increasing complexity of data flows and the opacity of AI systems necessitate a new RoPA: a living framework for data governance that transforms compliance into a real-time, strategic function. This new model must achieve three core objectives:

• First, it must map contractual obligations to actual processing activities by leveraging contract lifecycle management (CLM) platforms to interpret data processing terms. 
• Next, a dynamic vendor intelligence layer is required to account for all third-party vendors and their ecosystems. 
• Finally, a data discovery layer is needed to scan infrastructure and codebases in real time, comparing actual data handling with contractual obligations. 

An integrated governance process such as this could scan contracts to flag gaps, monitor data movement, and correlate access logs with privacy settings. In doing so, compliance teams would be empowered to become strategic enablers, supporting the safe and trusted scaling of data and AI innovation. Kamp concludes that the future lies in a convergence of data protection compliance, AI ethics, and cybersecurity into a unified, real-time governance function powered by AI and that organisations should begin building open, interoperable tools now, as manual ROPAs are no longer viable for an AI-driven world.