If you operate a WordPress website, you are, in many cases, required under the General Data Protection Regulation (GDPR) to maintain a Record of Processing Activities (ROPA). This isn’t just about data protection “behind the scenes,” but also about the specific tools, plugins, and form solutions you use on your site. In this article, you’ll learn what a ROPA is, when it becomes mandatory, and how to properly document typical WordPress-related processing activities – including helpful examples and recommendations.
What is a Record of Processing Activities (ROPA)?
According to Article 30 of the GDPR, the ROPA is an overview of all processes in which you process personal data on your website. This includes, among others:
- Contact forms
- Newsletter sign-ups
- Tracking and analytics tools
- User registrations
- Comment functions
- Security plugins (e.g., login attempts)
The ROPA documents WHO (you as the controller or service provider) processes WHAT, WHY, HOW, and FOR HOW LONG — and with WHOM the data may be shared.
When do you need a ROPA?
You need a ROPA if you regularly and automatically process personal data. This applies to almost all WordPress website owners – especially if you:
- offer a contact form,
- use Google Analytics, Matomo, or similar tools,
- use newsletter services such as Mailchimp or Brevo (formerly Sendinblue),
- run a membership system (e.g., WooCommerce, BuddyPress, LMS plugins),
- process personal IP addresses through security plugins such as Wordfence or Antispam Bee.
Conclusion: As a website owner, you generally can’t avoid maintaining a ROPA.
What must be included in the ROPA? – Typical entries for WordPress websites
Here are some concrete examples you should document for your WordPress site:
1. Contact form (e.g., with WPForms, Contact Form 7, or Formidable Forms)
- Purpose: Allowing visitors to get in touch
- Data categories: Name, email address, message content, IP address
- Recipients: Web host, possibly email service provider
- Legal basis: Art. 6(1)(b) GDPR (pre-contractual measure)
- Retention period: Until the request has been processed or in accordance with legal requirements
2. Newsletter subscription (e.g., with MailPoet, Mailchimp, Brevo)
- Purpose: Sending newsletters
- Data categories: Name, email address, opt-in date, IP address
- Recipients: Newsletter service provider
- Legal basis: Consent, Art. 6(1)(a) GDPR
- Retention period: Until consent is withdrawn or the user unsubscribes
3. Web analytics (e.g., Matomo, Google Analytics)
- Purpose: Measuring reach and user behavior
- Data categories: IP address (truncated or pseudonymized), website usage behavior
- Recipients: Provider of the analytics software, possibly hosting provider
- Legal basis: Consent, Art. 6(1)(a) GDPR (via cookie banner)
- Retention period: Varies depending on the tool (often 14 to 26 months)
4. Security plugins (e.g., Wordfence, iThemes Security)
- Purpose: Protection against attacks, login monitoring
- Data categories: IP address, login attempts, username
- Recipients: Security service provider
- Legal basis: Legitimate interest, Art. 6(1)(f) GDPR
- Retention period: Varies, e.g., 7–30 days
Practical tips: How to manage your ROPA efficiently
✅ Use templates
Many data protection generators and law firms offer ROPA templates as Word or Excel files. For WordPress websites, you can even find specialized versions (e.g., from eRecht24 Premium, datenschutz-generator.de, or privacy law firms like Spreu24).
✅ Use plugins for assistance
Some privacy plugins, such as Complianz or WP DSGVO Tools, provide internal lists of processing activities that you can export and use for your ROPA.
✅ Keep it up to date
If you install a new plugin or introduce new forms, the ROPA must be updated. Also pay attention to changes made by third-party providers (e.g., server location, subcontractors).
SEO tip: Why the ROPA also indirectly boosts your visibility
A properly maintained ROPA contributes to legal compliance and transparency — both key factors for building user trust and, ultimately, improving conversions. It also helps you clearly distinguish between legitimate interest and consent when using cookies and tracking tools — which, in turn, can positively impact loading speed, bounce rate, and GDPR-compliant rankings.
Conclusion: The ROPA is as essential to a WordPress website as the legal notice
Even though it may sound bureaucratic at first, the Record of Processing Activities protects not only your visitors but also you as the website owner. The more clearly you document what data you process, how, and why, the better prepared you’ll be in the event of a data protection audit — and the more trust you’ll inspire.
If you choose your WordPress plugins carefully and document the key tools, you’ll be on the safe side.