  The creation and maintenance of a Register of Processing Activities (ROPA) is
an essential process for the demonstration of GDPR compliance. We analyse ROPA
templates from six EU Data Protection Regulators and show that template scope
and granularity vary widely between jurisdictions. We then propose a flexible,
consolidated data model for consistent processing of ROPAs (CSM-ROPA). We
analyse the extent that the Data Privacy Vocabulary (DPV) can be used to
express CSM-ROPA. We find that it does not directly address modelling ROPAs,
and so needs additional concept definitions. We provide a mapping of our
CSM-ROPA to an extension of the Data Privacy Vocabulary.
