Thailand’s Office of the Personal Data Protection Committee (PDPC) recently released draft guidance on records of processing activities (ROPA) for personal data controllers and processors under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The draft guidance, which was presented to the public on July 7, 2026, addresses both controller records of collection, use, and disclosure of personal data and processor records of processing activities carried out on behalf of controllers. If implemented, the guidance will significantly expand organizational expectations for ROPA preparation, maintenance, and use across all sectors.

Key Takeaways

The draft guidance contains several important implications for organizations subject to the PDPA:

• ROPA reframed as a core accountability tool. The guidance elevates ROPA from an administrative record to a central accountability mechanism, connecting controller duties with recordkeeping obligations.
• ROPA as a source for privacy notices and governance documents. ROPA should serve as the primary source for privacy notices and align with consent management, retention schedules, DPIAs, incident response plans, and vendor contracts.
• Expanded scope across all activities. ROPA must cover all processing activities across the organization—including security, finance, HR, and external contractors—with correct controller or processor classification for each.
• Ongoing maintenance and auditability. ROPA must be updated for any change to systems, purposes, or processors, reviewed at least annually, and maintained with version control and a designated owner.
• Enhanced vendor, processor, and cross-border transfer requirements. Organizations must document all processors, external recipients, and cross-border transfers, specifying purposes, access scope, and destination countries.
• Linkage with risk assessment, DPIAs, and LIAs. ROPA should assign risk levels to each activity and identify when data protection impact assessments (DPIAs) or legitimate interests assessments (LIAs) are required, functioning as a risk-management tool.
• ROPA and data breach readiness. Incomplete ROPA can delay breach response and notification. Organizations should map data flows, vendors, and security measures in advance.

Potential Impact

The draft guidance will require operational and governance changes for most organizations:

• Operational overhaul. Organizations will need to expand ROPA beyond IT to cover all departments and activities, including HR, marketing, security, and finance.
• Governance alignment. ROPA must align with privacy notices, consent management, retention schedules, DPIAs, incident response plans, and vendor contracts, requiring cross-functional coordination.
• Vendor management. Organizations must identify all processors, subprocessors, external recipients, and cross-border transfers; document access scope and destination countries; and execute data processing agreements.
• Ongoing maintenance costs. Annual reviews, version control, change logs, and mandatory pre-launch updates will create recurring compliance workloads.
• Marketing and AI activities. Higher-risk processing activities, including certain targeted marketing, customer behavior analysis, and AI-based tools may require DPIAs before launch.
• Breach response preparedness. Organizations with incomplete ROPA may face delayed breach notifications and regulatory scrutiny.

The highest-risk areas include incomplete activity inventories, incorrect controller/processor classification, failure to identify lawful bases or retention periods, missing vendor or cross-border records, and lack of auditability.

Strategic Outlook

As the draft guidance continues to move toward formal adoption, organizations can use it as a prompt to refresh their data maps, ROPA templates, privacy notices, consent management, retention schedules, DPIA and LIA triggers, vendor contracts, and breach response documentation before the guidance is finalized. Specific actions organizations can take based on the current draft include:

• Preparing ROPA as an organization-wide register covering all processing activities, not just IT systems.
• Mapping whether each party is a controller or processor for each activity.
• Assigning a ROPA owner, implementing version control, and maintaining a change history.
• Requiring ROPA updates before launching new systems, adding new purposes, changing processors, or introducing new technologies.
• Identifying all processors, subprocessors, external recipients, and cross-border transfers with documented purposes, access scope, and destination countries.
• Using ROPA to identify high-risk activities and trigger DPIAs or LIAs where appropriate.

With this indication that the PDPC expects ROPA to assume a more central role in organizational privacy compliance programs, organizations that adjust their ROPA practices to match these new expectations will be better placed to demonstrate accountability and respond quickly in PDPC-related matters.