The Bavarian State Office for Data Protection (BayLDA) has issued a “Short information” entitled “Spring cleaning of the processing directory”. published, with a focus on the directories of public authorities. The core statement is that a processing directory must not only be created, but also regularly maintained must be.
It is clear from the explanations, among other things, that the responsible person may choose “a rather global view”, i.e. keep the granularity of the entries relatively low. However, he must then also check whether a new activity has an effect on the entry, e.g. because a new category of recipients is added.
The following statement is also nice:
Always keep in mind that keeping the processing directory up to date is not a pointless job creation measure, neither for the data protection officers managing the processing directory nor for the managers responsible for data protection. If the impression is otherwise, the data protection organization at the controller in question has not yet been sufficiently optimized.