For communications services and features, review whether the service listens to, taps, stores, intercepts, monitors, records, analyzes, or otherwise accesses communications content or related traffic data. The ePrivacy Directive requires confidentiality of communications and related traffic data, subject to narrow exceptions such as user consent, legal authorization, technical storage necessary for conveyance, and lawful business recording for evidence of a commercial transaction or business communication.
For traffic data, location data, and value-added services, record the purpose, duration, user information, consent or anonymization basis, withdrawal route, and personnel restrictions. Do not reuse communications data for marketing, analytics, or value-added services without the required basis and transparency. If the organisation provides a publicly available electronic communications service, also run the Article 4 security and personal-data-breach branch.