The way art 30(5) is drafted though means that the exception applies to basically nobody. Unfortunately, this is a good demonstration of two criticisms made of

The way art 30(5) is drafted though means that the exception applies to basically nobody. Unfortunately, this is a good demonstration of two criticisms made of the GDPR right from the start: the costs of creating new paperwork in the approved format even if it makes no material difference to any actual data processing, and ambiguity about what is required or permitted even in quite fundamental respects.