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Privacy Impact Assessments

Run Data Protection Impact Assessments (DPIAs/PIAs) to identify and mitigate privacy risk before high-risk processing begins.

Compliance intermediate ⏱ 40 min

Privacy Impact Assessments

Overview

A Privacy Impact Assessment (PIA) — called a Data Protection Impact Assessment (DPIA) under GDPR — is a structured process to identify, assess, and mitigate privacy risks before a project or system processes personal data. It is the practical embodiment of “data protection by design” and a cornerstone of demonstrable accountability.

Why It Matters

  • Legal trigger: GDPR Article 35 makes a DPIA mandatory for processing “likely to result in a high risk” — and failure to conduct one is independently sanctionable.
  • Risk prevention: Catching privacy risks at design time is far cheaper than remediating a live system or a breach.
  • Evidence: A documented DPIA is primary evidence of compliance during audits and investigations.

Key Regulations & Frameworks

  • GDPR Articles 35 & 36 — DPIA requirement and prior consultation with the supervisory authority for high residual risk.
  • WP29/EDPB DPIA guidelines (WP248) — nine criteria for “likely high risk” processing.
  • ICO DPIA guidance and CNIL PIA methodology + open-source software.
  • ISO/IEC 29134 — guidelines for privacy impact assessment.

Core Requirements

  1. Screening — determine whether a DPIA is required (high-risk triggers: large-scale special categories, systematic monitoring, new technologies, automated decisions).
  2. Description of processing — purposes, data, recipients, retention, and data flows.
  3. Necessity & proportionality — lawful basis, minimization, and whether the goal can be met with less data.
  4. Risk assessment — likelihood and severity of harm to data subjects.
  5. Mitigation — controls to reduce risk to an acceptable level.
  6. Sign-off & review — DPO advice, decision record, and review on material change.

Best-Practice Checklist

  • Embed DPIA screening into project intake and change management
  • Use the EDPB nine-criteria test to decide when a DPIA is required
  • Document processing, data flows, and lawful basis
  • Score risks by likelihood and severity to data subjects
  • Record mitigations and residual-risk decisions
  • Obtain DPO advice and, where high residual risk remains, consult the regulator
  • Schedule periodic DPIA review and update

Resources


Guidance only — DPIA triggers and templates vary; align with your regulator’s methodology.