In discussing  Data Processing  Data Disclosure today 

Let me bring to your kind attention the followings;:

Some elementary dedfinition of data proccessing

"Data processing is the conversion of data into usable and desired form. This conversion or “processing” is carried out using a predefined sequence of operations either manually or automatically. Most of the data processing is done by using computers and thus done automatically. The output or “processed” data can be obtained in different forms like image, graph, table, vector file, audio, charts or any other desired format depending on the software or method of data processing used 

Data processing  may involve 

• Validation  – Ensuring that supplied data is correct and relevant.
• sorting – "arranging items in some sequence and/or in different sets."
• Summarization – reducing detail data to its main points.
• Aggregation – combining multiple pieces of data.
• Analysis – the "collection, organization  analysis, interpretation and presentation of data."
• Reporting – list detail or summary data or computed information.
• Classification – separation of data into various categories.

Data processing also referred to as "the collection  and manipulation of items of data to produce meaningful information. In this sense it can be considered a subset of information processing , "the change (processing) of information in any manner detectable by an observer."

Having said that I wish to recall that :

1. you referred to Article 2 of GPDR stating that data proccessing is associated with sata disclosure in that Article.May you kindly advise which part of Article 2 such reference  is made 

2. You talked about data disclosure while we were discussing Data Access or Data Transfer these are totally different things

3. If anyone says that Data Transfer or data access is part of data process, it is  not totally valid .It is preferable that analysis of these two totally different issues  be done from technical point of view  and are left to technical people

One can once collects data does make  nothing  or either transfer that unprocessed data to a recipient or record that data elsewhere . That entity could also process the date (,Data Processing  ) as described above.

I therefore request you to kindly make difference between " Data Process" , ",Data transfer " which may roughly referred as " Data Transfer ".

One should allow the  expert in data Communication express their views without misleading by mixing " Data Process" , ",Data transfer " which may roughly referred as " Data Transfer ".

When people refers to GDPR needs to recognized that the authors were mostly administrative and legal people without engineering background. They normally good to write theoretical text in form of policy without acknowledging their implementations

For some of us data Access may have little sense whereas for many others the  purpose of Data Access , among other things are  law enforcement, combating cybercrime, countering cyber-attack and preserve the security, stability and resiliency of DNS not merely from preservation of commercial interests but for establishing/ maintaining public order 

Regards

Kavouss