Data Privacy Impact Assessment (DPIA)

What is Data Privacy Impact Assessment (DPIA)?

 

Also known as Data Protection Impact Assessment, Data Privacy Impact Assessment (DPIA) is a type of test required under the General Data Protection Regulation (GDPR) for any project that has the potential to put other parties’ information at a high risk of being compromised. It is designed to help teams identify and address potential data protection issues that may arise during the course of the project.

 

If you wish to learn more about this topic, check out the FAQ section below:

 

Question #1: What types of projects require a Data Privacy Impact Assessment (DPIA)?

 

According to the GDPR website, for a project to require a Data Privacy Impact Assessment (DPIA), it has to satisfy seven basic conditions:

 

1. It involves the use of new technologies
2. It involves the tracking of user location or behaviour
3. It involves the systematic monitoring of a public space on a massive scale
4. It involves the processing of personal user data, including:
   1. Race
   2. Ethnicity
   3. Religious/philosophical beliefs
   4. Political opinions
   5. Trade union membership
   6. Genetic and/or biometric data (to uniquely identify a user)
   7. Health records
   8. Sex life and/or sexual orientation
5. It involves the processing of data to make automated user-related decisions that could have legal and similar implications
6. It involves the processing of data related to children
7. It involves the processing of user data that could cause physical harm if leaked

 

These, however, are just general conditions. Even if the specific project you are working on does not technically satisfy any of the items listed above, as long as it involves the handling of other people’s personal data, then it would still be a good idea to perform a Data Privacy Impact Assessment (DPIA).

 

Question #2: What does a Data Privacy Impact Assessment (DPIA) consist of?

 

According to the guidelines specified under the GDPR, a Data Privacy Impact Assessment (DPIA) must consist of the five basic elements:

 

1. A detailed description of the planned processing operations
2. A detailed description—including the legitimate interest being pursued by the person or team in charge—of the purposes of said processing
3. A detailed assessment of how necessary and proportionate the processing operations are against the purposes outlined
4. A detailed assessment of all the risks the rights and freedoms of all data subjects will be subjected to
5. A detailed description of the measures to be put in place to address the risks outlined, demonstrating compliance with the GDPR and taking the legitimate interests and rights of all concerned parties into account

 

Let us take a closer look at each one:

 

First, your Data Privacy Impact Assessment (DPIA) needs to clearly describe how you plan to collect, process, and use whatever user data you collect through and in relation to the project.

 

Second, it needs to clearly describe why you are collecting, processing, and using said data.

 

Third, it needs to assess if your collection, processing, and use of said data is actually necessary and proportionate to the objectives you have outlined.

 

Fourth, you need to go over all the rights and freedoms of all concerned parties and check whether any component of your collection, processing, and use of said data could put any of them at risk.

 

Finally, it needs to clearly describe how you plan to address any risks and potential privacy issues you find, including any measures, tools, and technologies you will use to do so.

 

Question #3: Is there a Data Privacy Impact Assessment (DPIA) template I can use?

 

Yes, there is a Data Privacy Impact Assessment (DPIA) template you can use, so you do not have to make one from scratch. You can access it here. The template will also help you determine whether or not the project you are working on actually requires a Data Privacy Impact Assessment (DPIA).

 

Alternatively, if your team has a data protection officer, then you can also ask them for guidance and assistance.