Data protection is imperative when most of our sensitive information is stored online. Individual and organizational data is accessible to technologies such as artificial intelligence systems and other digital platforms, so proactively identifying and mitigating privacy risks to safeguard data is key.
A Data Protection Impact Assessment (DPIA) is a process designed to help organizations analyze how personal data is collected, used, stored, and protected. In completing the assessment, you receive a breakdown of the data being collected, a detailed look at potential privacy risks to that data, and suggestions for preventing any negative outcomes or compliance issues. Dataguard.com reports that, “To reduce the likelihood of data breaches and non-compliance penalties, a DPIA is a preventative measure that aligns with accountability and transparency principles.”
Steps for conducting a DPIA include:
- Identify the need for a DPIA
- Describe the processing
- Consult with stakeholders
- Assess necessity and proportionality
- Identify and assess risks
- Identify measures to mitigate risks
- Document, approve, and review
It’s a dynamic, flexible process rather than a strict list of boxes to check, but having a roadmap is the best way to start.
1. Identify the need for a DPIA
Typically, the need for a DPIA arises with the introduction of a new project, particularly where personal data processing is likely to result in a high risk to individuals’ rights and privacy. This includes situations involving new technologies, large-scale processing, or sensitive data. A DPIA may also be required when significant changes are made to existing processing activities. Conducting a DPIA early helps identify risks, ensure compliance, and support accountability.
2. Describe the processing
This step means creating a summary of how the processing operates in practice. It should describe the full data lifecycle, including how personal data is collected, used, stored, shared, and retained, along with system interactions, access controls, and any third-party involvement. The description should cover the gamut and provide enough detail to support an informed assessment of risks.
3. Consult with stakeholders
Stakeholders need clear information about how, why, and what data will be used; the potential risks to individuals; and the methods proposed to reduce those risks. Under the General Data Protection Regulation, this may also include seeking input from those whose data is involved, or their representatives. Ensure that stakeholders and their needs are integrated from the start.
4. Assess necessity and proportionality
Assessing necessity and proportionality in a DPIA means evaluating whether the data processing is truly required for the project, and whether the data processing is being properly minimized. Checking in with the legal guidelines and exploring alternatives covers those bases.
5. Identify and assess risks
It’s important to look at how the proposed data processing could cause harm and how likely it is. Risks like data leaks, unauthorized access, misuse of personal information, wrongful outcomes from automated decisions, or other harms to privacy and rights. Judge each risk based on its likelihood and potential severity to determine which issues need the most attention and control under the aforementioned GDPR.
6. Identify and decide how to mitigate risks
Once risks have been identified and assessed, they must then be guarded against. Technological preventative measures can be implemented, like data encryption and access restrictions, and organizational ones, like trainings and policy updates.
7. Document, and review, and approve
The DPIA complete, record all the findings in appropriate detail, then review them for accuracy. Have everyone involved in the DPIA sign off on it, and put it to use.
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