- Rezervarea
- Name, phone number, date and time, number of people, table, sometimes occasion. It is the most common set of data in a venue and, taken on its own, the simplest: it relies on performance of the contract or on steps taken at the request of the person before the contract. The complication comes from the channel, not the content — the same reservation exists simultaneously in the bar notebook, in the page’s messaging thread and in the external booking service, and the third is the only one someone might call a “system”. Each copy has its own recipient, its own storage place and its own term, and all three must be described in the record of processing activities.Keep: Regarding the purpose of the reservation and what follows it. The anticipated deletion periods by category are an express element of the record of processing activities — so they are decided and written down, not left to the application’s default behaviour.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 5 para. (1) lit. e), art. 30 para. (1) lit. c), d) and f)
- Allergy or dietary requirement note
- “Gluten-free”, “peanut allergy”, “does not eat dairy”. By its content, this is health data, so it is a special category, regardless of the fact that it was written in a box called “notes”. It needs its own exception — in practice, explicit consent for specific purposes — and a separation that systems do not make on their own: the information is needed by the kitchen that evening and is not needed for any other purpose. The same sentence, moved from the order receipt to the client profile, changes its regime, because it changes its purpose, and the compatibility of a new purpose is assessed against explicit criteria, including the nature of the data and the possible consequences for the person.Keep: How long the purpose for which it was given lasts — the service from that evening. Retention in a client profile is a second purpose, with a second basis and a second term, and consent can be withdrawn as easily as it was given.SourceLaw 195/2024, art. 4 (the definition of “health data”), art. 9 para. (1) and (2) lit. a), art. 6 para. (5), art. 7 para. (3)
- Traceability record
- The product description, quantity, batch reference, dispatch date and — the surprising part — the name and address of the sender and of the recipient. When the supplier is a sole trader or an individual producer, the food safety record also contains personal data, although no one treats it as such. It is not a reason not to keep it; it is a reason for it to appear in the record of processing, with its real purpose, which is a legal obligation, not marketing.Keep: At least 14 days from the expiry date, from the date of minimum durability or from the last day of the shelf life, with daily updating. At the Agency’s request, the information is provided within 5 days.SourceLaw 306/2018, art. 11 para. (5), (6) and (7); Law 195/2024, art. 6 para. (1) lit. c), art. 30 para. (1) lit. b) and f)
- HACCP documentation and monitoring records
- Risk analysis, critical points, limits, temperature monitoring records, corrective actions and periodic checks. The law expressly requires the preparation of documents and records depending on the nature and size of the undertaking, so that the effective application of the measures can be demonstrated. Most of it does not contain personal data, but the records signed by the person who measured and by the person who corrected do contain it — and those are both evidence and processing.Keep: Unverified for the specific term. The law refers to Law no. 880/1992 on the Archival Fund of the Republic of Moldova for the retention of HACCP implementation documents; we were unable to open the text of that law on the day of verification, and a number of years that I cannot show remains unverified.SourceLaw 296/2017, art. 3 para. (7) lit. g), art. 8 para. (1) lit. a) and b)
- Staff health file
- The medical booklet, the medical examination at hiring, periodic examinations, communicating an illness or symptoms to the controller, the prohibition on entering the handling area for anyone suffering from infected lesions, skin infections, abscesses or diarrhoea. These are health data about employees, required by law, so impossible to avoid — and that is why the only question left is who sees them. The measures must ensure that, by default, the data cannot be accessed, without the person’s intervention, by an unlimited number of persons; a dossier shared on the manager’s phone does not meet the condition.Keep: Unverified for the sectoral term. The general principle is retention for a period that does not exceed what is necessary for the purpose, and the anticipated term by category is entered in the record of processing activities.SourceLaw 296/2017, art. 16 para. (1)–(3); Law 306/2018, art. 23 para. (1) and (2); Law 195/2024, art. 9 para. (2) lit. b), art. 25 para. (2), art. 5 para. (1) lit. e)
- Images from the video surveillance system
- The cameras above the house, at the entrance and in the serving area film customers and employees alike. It is processing, it needs a lawful basis and information at the moment of collection — that is, at the entrance, not in a policy hidden on the site. And if the coverage turns into systematic large-scale monitoring of an area accessible to the public, a data protection impact assessment is required before installation, not after the first complaint.Keep: Determined by purpose and explicitly written; the principle of storage limitation applies in full. The planned deletion term is an element of the record of processing activities.SourceLaw 195/2024, art. 6 para. (1) lit. f), art. 13 para. (1) and (2), art. 35 para. (1) and (3) lit. c), art. 30 para. (1) lit. f)
- Delivery order
- The address, floor, intercom code, phone number, sometimes directions about who opens the door. They are collected for a single purpose — so the food arrives — and have a short life cycle by nature, but remain in the order table as long as the price and quantity. This also includes the information obligation under the food law: when sold by means of distance communication, the mandatory information is provided before purchase, on the distance-selling medium, at no additional cost to the consumer, and all mandatory mentions at the time of delivery.Keep: Regarding the fulfilment of the order and the obligations arising from it. The term is decided by category and written in the record; access fields for the dwelling do not need the same term as the order record.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 5 para. (1) lit. c) and e), art. 30 para. (1) lit. f); Law 279/2017, art. 12 para. (1) and (2)