The actual usage of the personal data which can be anything from collecting, storing or destroying the personal data. Processing of data is a primary condition for GDPR to be applicable.

Processing is defined in Art. 4(2) GDPR as:

“Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”