Amendment 1600· GDPR Article 30(5a) (new)
+Addition
Text of the amendment
As tabled
Amending instruction
In Article 30, paragraph 5a is added
Wording it would add
Paragraphs 1-4 shall not apply to associations, foundations, and other non-profit organisations whose processing activities are limited to the purposes described in Article 13(6).
Wider passage printed with the amendment
Article 30 Records of processing activities 1. Each controller and, where applicable, the controller’s represen tative, shall maintain a record of processing activities under its respon sibility. That record shall contain all of the following information:
(a)the name and contact details of the controller and, where applicable, the joint controller, the controller’s representative and the data protection officer; (b) the purposes of the processing; (c) a description of the categories of data subjects and of the categories of personal data; (d) the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or inter national organisations;
(e)where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the docu mentation of suitable safeguards; (f) where possible, the envisaged time limits for erasure of the different categories of data; (g) where possible, a general description of the technical and organisa tional security measures referred to in Article 32(1). 2. Each processor and, where applicable, the processor’s representa tive shall maintain a record of all categories of processing activities carried out on behalf of a controller, containing: (a) the name and contact details of the processor or processors and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s represen tative, and the data protection officer; (b) the categories of processing carried out on behalf of each controller; (c) where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the docu mentation of suitable safeguards; B (d) where possible, a general description of the technical and organisa tional security measures referred to in Article 32(1). 3. The records referred to in paragraphs 1 and 2 shall be in writing, including in electronic form. 4. The controller or the processor and, where applicable, the controller’s or the processor’s representative, shall make the record available to the supervisory authority on request. 5. The obligations referred to in paragraphs 1 and 2 shall not apply to an enterprise or an organisation employing fewer than 250 persons unless the processing it carries out is likely to result in a risk to the rights and freedoms of data subjects, the processing is not occasional, or the processing includes special categories of data as referred to in Article 9(1) or personal data relating to criminal convictions and offences referred to in Article 10.
GDPR Article 30 with this amendment
Amendment 1600 applied to the Commission proposal, no other amendment
Unchanged: (1), (2), (3), (4) and (5)
Each controller and, where applicable, the controller’s representative, shall maintain a record of processing activities under its responsibility. That record shall contain all of the following information:
the name and contact details of the controller and, where applicable, the joint controller, the controller’s representative and the data protection officer;
the purposes of the processing;
a description of the categories of data subjects and of the categories of personal data;
the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations;
where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards;
where possible, the envisaged time limits for erasure of the different categories of data;
where possible, a general description of the technical and organisational security measures referred to in Article 32(1).
Each processor and, where applicable, the processor’s representative shall maintain a record of all categories of processing activities carried out on behalf of a controller, containing:
the name and contact details of the processor or processors and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s representative, and the data protection officer;
the categories of processing carried out on behalf of each controller;
where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards;
where possible, a general description of the technical and organisational security measures referred to in Article 32(1).
The records referred to in paragraphs 1 and 2 shall be in writing, including in electronic form.
The controller or the processor and, where applicable, the controller’s or the processor’s representative, shall make the record available to the supervisory authority on request.
The obligations referred to in paragraphs 1 and 2 shall not apply to an enterprise or an organisation employing fewer than 250 persons unless the processing it carries out is likely to result in a risk to the rights and freedoms of data subjects, the processing is not occasional, or the processing includes special categories of data as referred to in Article 9(1) or personal data relating to criminal convictions and offences referred to in Article 10.
Paragraphs 1-4 shall not apply to associations, foundations, and other non-profit organisations whose processing activities are limited to the purposes described in Article 13(6).
+NewJustification
Record-keeping obligations under Article 30 should be proportionate to the actual risk of the processing activity. Small non-profit organisations, associations and foundations often lack dedicated compliance structures and process data only for limited internal administrative purposes. Requiring full records of processing activities in such low-risk cases creates administrative burdens without a corresponding benefit for data subjects. This amendment clarifies that the exemption applies to non-profit organisations where processing is limited to the purposes set out in Article 13(6), while preserving the full obligation where processing is likely to result in a high risk to the rights and freedoms of data subjects.
Target
Wording of the targeted provisionlaw in force, Commission proposal, latest Council text
No Council text amends Article 30(5a) (new).
Cite this amendment
Amendment 1600 (Andrea Wechsler and others), European Parliament, Committee on Industry, Research and Energy and Committee on Civil Liberties, Justice and Home Affairs, amendments 1565–1740 to the draft report on COM(2025) 837 (CJ72-AM-791874, PE791.874v01-00, 27 July 2026), pp. 53–55
Link, short form and official text
Amendment 1600 (Andrea Wechsler and others), European Parliament, Committee on Industry, Research and Energy and Committee on Civil Liberties, Justice and Home Affairs, amendments 1565–1740 to the draft report on COM(2025) 837 (CJ72-AM-791874, PE791.874v01-00, 27 July 2026), pp. 53–55
ITRE–LIBE Amendment 1600 (CJ72-AM-791874), p. 53