Article 4 (6) of the GDPR sets the definition for a ‘filing system’. If the personal data that the company processes manually is in structured form and the processing is conducted in a database, then yes GDPR does apply. If the processing is one-off and the company does not use a database, then GDPR might not apply.
What are the records of processing activities (ROPA)? Article 30 of the EU General Data Protection Regulation (GDPR) requires organisations to maintain internal records, which