GDPR accountability obligations
Under GDPR Article 5(2), data controllers must demonstrate compliance with data protection principles. This accountability principle requires organisations to prove not just what they did, but when they did it. When was consent collected? When was data deleted? When was a data subject access request fulfilled? Without timestamped evidence, these questions become difficult to answer.
Timestamping consent records
When a user gives consent for data processing, timestamping the consent record immediately creates irrefutable proof of when consent was obtained. If the user later disputes the timing, the qualified timestamp serves as evidence in the organisation's favour. This is particularly important for marketing consent under the ePrivacy Directive.
Proving deletion compliance
When a data subject requests erasure under Article 17, the organisation must delete the data within a reasonable timeframe. Timestamping the deletion log entry proves exactly when the deletion occurred. This evidence is crucial during DPA investigations and can prevent significant fines.
Audit trail integrity
GDPR compliance audits rely on processing logs. If these logs can be altered, their evidentiary value is questionable. Timestamping log entries with a qualified TSA makes the audit trail tamper-evident, giving supervisory authorities confidence in the organisation's compliance claims.