Turning a multinational corporation’s strong privacy commitment into business-as-usual
Snapshot
Turning Complexity into Confidence.
ROPAs (Records of Processing Activities) are essential for privacy compliance under GDPR Article 30, yet many enterprises struggle to maintain clarity, consistency, and ownership across departments. One multinational retailer faced mounting operational burdens and ambiguity in its ROPA management. With unclear accountability, overly granular records, and a fast-approaching recertification cycle, the organization turned to Kalles Group to stabilize its privacy commitments and operationalize a more intuitive, sustainable solution.
Challenge
When Ownership Gaps and Overly Granular Records Stall Progress.
Despite having strong privacy intentions, the client’s ROPA program lacked clear ownership and suffered from unnecessary complexity. Previous consultants had built out over 60 distinct ROPAs, many of which overlapped or repeated vendor processes with slight variations. The result: a time-consuming and confusing process for both the privacy team and business users completing surveys.
Making matters more urgent, a privacy lead responsible for ROPA recertification had recently transitioned to a new role, creating an immediate operational gap. Onboarding new staff into a flawed process without clear KPIs or accountability risked derailing recertification and exposing the company to regulatory consequences.
The client needed help clarifying who was responsible for what, understanding which metrics to track, and reducing unnecessary complexity in ROPA documentation, especially for areas involving multiple vendors, like internal employee monitoring systems.
Approach
Strategic Overhaul Backed by Practical Tools.
Kalles Group provided an expert consultant through its On-Demand Resourcing (ODR) program to immediately fill the vacated role and stabilize operations. But beyond simply backfilling a position, the consultant drove a strategic redesign of the ROPA program.
Clarifying Ownership: We worked cross-functionally with the privacy team, legal, and IT partners to assign ownership roles across each tool and data processing activity. This clarity meant that future updates could be managed without friction or guesswork.
Reframing Metrics: Kalles Group established a risk management roadmap and developed KPIs tailored to each stakeholder group. These included:
- High-level summary metrics for leadership oversight
- Operational status indicators for the privacy team
- Agile-friendly metrics for sprint planning and milestone tracking
Redesigning the Survey Experience: We identified key usability pain points in the ROPA intake process and overhauled the survey to make it more intuitive. This significantly improved the quality of incoming data and reduced the need for manual clarification.
Consolidating ROPAs: Using an analysis of processing activities, we combined granular and redundant entries. For example, we consolidated over 25 vendor-specific entries under “Internal and Employee Activity Security Monitoring” into one master record. This reduced survey fatigue and increased data consistency across departments.
To further support ROPA and privacy operations, we also recommended enhanced tooling aligned with application security solutions and controls to mitigate BYOD risks, strengthening the overall security framework around employee and vendor data access.
Results
ROPA as a Scalable, Business-as-Usual Process.
By the end of the engagement, ROPA management had transitioned from a fragmented and stressful initiative into a structured, business-as-usual process. The privacy team could confidently track, update, and report on data processing activities without relying on institutional memory or last-minute fire drills.
Key Outcomes Included:
- Reduction of 60+ ROPAs down to 7 strategically grouped master records
- Streamlined survey tools that decreased average completion time by over 30%
- Defined ownership across all tools and systems related to data processing
- Clear metrics tied to performance, recertification progress, and stakeholder reporting
Perhaps most notably, consolidating the Internal/Employee Activity Security Monitoring ROPA across 25 vendors served as a model for how consolidation can significantly reduce operational friction. This initiative enabled the client to maintain compliance with GDPR and other global data privacy standards without the previous overhead or confusion.