Data Protection Impact Assessment

A detailed, factual account of the planned data flows. This component establishes the factual baseline for the entire assessment.

• Nature: Categories of data subjects and personal data (e.g., biometric, health, location).
• Scope: Volume, frequency, and duration of processing.
• Context: The relationship between the controller and data subjects, and the level of control subjects have.
• Purposes: The specific, explicit, and legitimate business objectives.
• Technical Assets: A map of systems, including data lineage from ingestion to deletion.

A rigorous legal test proving that the processing is essential and balanced. It justifies why a less intrusive method cannot achieve the same purpose.

• Purpose Limitation: Verifying the processing aligns with the original legitimate interest assessment.
• Data Minimization: Confirming only adequate, relevant, and limited data is collected.
• Necessity Proof: Demonstrating why the specific high-risk processing is indispensable.
• Compliance Check: Cross-referencing against all other GDPR obligations, including transparency and storage limitation.

An evaluation of the potential physical, material, or non-material damage to natural persons. This moves beyond organizational risk to focus on the individual.

• Source Identification: Pinpointing threats from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure.
• Impact Analysis: Predicting consequences like discrimination, identity theft, financial loss, or social disadvantage.
• Likelihood & Severity: Scoring risks based on probability and potential harm, often using a matrix to calculate residual risk.
• Vulnerable Subjects: Special consideration for children, employees, or patients where a power imbalance exists.

A concrete action plan of technical and organizational controls designed to eliminate or reduce identified risks to an acceptable level.

• Technical Controls: Implementing differential privacy, pseudonymization, encryption at rest and in transit, and strict access controls.
• Organizational Controls: Staff training, internal privacy policies, and binding processor agreements.
• Contestability Mechanisms: Interfaces allowing subjects to exercise their right to explanation and challenge solely automated decisions.
• Residual Risk Acceptance: A formal sign-off by the Data Protection Officer confirming that the remaining risk is proportionate to the societal benefit.