Data protection for private individuals in Switzerland

Art. 12 FADP

Record of processing activities

Chapter 2: General ProvisionsSection 1: Definitions and Principles

Statutory textStatus: 7 July 2025

1 The controller and the processor shall each maintain a record of their processing activities.

2 The controller's record shall as a minimum contain:

  • a.

    the identity of the controller;

  • b.

    the purpose of processing;

  • c.

    a description of the categories of data subjects and the categories of processed personal data;

  • d.

    the categories of recipients;

  • e.

    if possible, the retention period for the personal data or the criteria for determining this period;

  • f.

    if possible, a general description of the measures taken to guarantee data security under Article 8;

  • g.

    if the data are disclosed abroad, details of the State concerned and the guarantees under Article 16 paragraph 2.

3 The processor's record shall contain information on identity of the processor and of the controller, the categories of processing carried out on behalf of the controller, and the information mentioned in paragraph 2 letters f and g.

4 The federal bodies shall notify the FDPIC of their records of processing activities.

5 The Federal Council shall provide exceptions for legal entities that have fewer than 250 employees and whose data processing poses a negligible risk of harm to the personality of the data subjects.

Source: Version on FedlexThis translation is not an official version. Only the German, French and Italian versions are legally binding.

In brief

Companies and service providers must keep a record of processing activities: what they process and why, to whom they disclose data and how long they keep it. Small companies with fewer than 250 employees and a low risk are exempt.

What does this mean for me?

The record is not public. But it helps the company to answer your access request in full.

Implementing provisions in the Data Protection Ordinance (DPO)

  1. Art. 24 DPOExemption from the obligation to keep a record of processing activities

Explanation by mydatenschutz.ch in plain language – not legal advice. The statutory text is authoritative.