DPIA Methodology

A Data Protection Impact Assessment (DPIA) is a systematic process to identify, evaluate, and mitigate the data protection risks of a project. It is a core tool for accountability and risk management.

When is a DPIA Required?

Under GDPR Article 35, a DPIA is mandatory when processing is "likely to result in a high risk" to rights and freedoms. This includes: systematic and extensive evaluation of personal aspects (profiling); large-scale processing of special categories of data (health, biometric); or systematic monitoring of publicly accessible areas (CCTV). Regulators also publish "Blacklists" of operations requiring DPIA, such as using new technologies, processing location data, or matching datasets.

The DPIA Process

1. Identify Need: Conduct a threshold assessment to determine if a full DPIA is required. 2. Describe Processing: Document the nature, scope, context, and purposes of processing. Create data flow diagrams. 3. Assess Necessity: Verify that the processing is necessary and proportional to the purpose. Are there less intrusive ways to achieve the goal?

4. Identify Risks: Analyze potential risks to data subjects (e.g., discrimination, identity theft, loss of control). Consider confidentiality, integrity, and availability. 5. Mitigate Risks: Define technical (encryption, access control) and organizational (policies, training) measures to reduce risks to an acceptable level. 6. Sign-off: The Data Protection Officer (DPO) provides advice. Management decides whether to proceed. 7. Consultation: If high risks cannot be mitigated, the Supervisory Authority must be consulted before processing begins.

Documentation

The DPIA report is a living document. It should include the project description, legal basis analysis, risk assessment matrix, and the action plan. It must be reviewed regularly, especially when changes occur in the processing activity.