The under-250-employee exemption does not apply because processing is regular, not occasional. The model's docstrings would allow generating the "categories of personal data" section of the Verzeichnis from the SQLAlchemy models with a small script, keeping documentation and schema in sync.
The under-250-employee exemption does not apply because processing is regular, not occasional. The model's docstrings would allow generating the "categories of personal data" section of the Verzeichnis from the SQLAlchemy models with a small script, keeping documentation and schema in sync.