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Data protection basics

What Is a Data Protection Impact Assessment (DPIA)?

Learn what a DPIA is, when you need one, and how to run structured assessments that regulators and customers can trust.

January 10, 2025
5 min read

A Data Protection Impact Assessment (DPIA) is a structured way to understand how a project, system or process affects the privacy of individuals. In practice, a DPIA forces you to slow down, list what data you collect, look at where it flows, and document the risks that could impact people if something goes wrong.

Regulators such as the European Data Protection Board repeatedly stress that DPIAs are not just a form to fill once. They are a living assessment that should be revisited whenever the risk profile of your product or processing changes.

Summary and key takeaways

  • 1A DPIA is required when processing is likely to result in a high risk to people.
  • 2The assessment must be documented in a way that a regulator can follow.
  • 3You need to describe the nature, scope, context and purposes of processing.
  • 4Risks should be linked to specific controls, mitigations and decisions.
  • 5Automation can help structure the work but cannot remove human accountability.

When do you need to run a DPIA?

Many teams only think about DPIAs when someone in legal sends them a template. A better way is to ask early, "Could this initiative meaningfully change how we collect, share or analyze personal data?" If the answer is yes, you at least need a lightweight screening.

National regulators publish lists of activities that almost always require a DPIA. Common triggers include: - Large-scale monitoring of behavior or location. - Systematic profiling with legal or financial effects. - Combining datasets from different sources to create new insights. - Handling sensitive categories of data such as health, biometrics or beliefs.

The DPIA is not there to block innovation. It exists to make sure you understand the risk, talk through alternative designs and record why you chose the approach you did.

Key steps in a DPIA

Step 1 – Describe the project in plain language

The first step is to write what you are doing in words a non-technical person could understand. Avoid jargon. Explain who the project is for, what problem you are solving and how personal data fits into that story.

Step 2 – Map the data

Next, you list what personal data is collected, where it comes from, who can see it and where it is stored. This is where teams discover surprises: extra logs, background analytics or copies sitting in test systems.

Step 3 – Identify risks to people

Risks in a DPIA are not only "we might get fined". Instead, you focus on what could happen to real individuals: - Could they lose money? - Could their reputation be harmed? - Could they be excluded or discriminated against? - Could sensitive facts about them be exposed?

Step 4 – Link risks to controls

For each risk, you document the existing controls and where you need improvements. This is where security, engineering, product and legal need to work together. Technical controls (encryption, access control), organizational controls (training, policies) and process controls (approvals, reviews) should all be considered.

Step 5 – Record decisions and follow-up actions

A DPIA is only useful if it leads to decisions. In some cases, you might change the design to remove a risky feature. In others, you may accept the risk but add monitoring and mitigation. Either way, the decision and rationale must be captured.

Automating DPIAs with assessment engines

Doing all of this manually in documents and spreadsheets becomes painful as soon as you have more than a handful of products or clients. That is why many teams are moving towards structured DPIA workflows in specialized tools.

An assessment engine can: - Provide reusable templates aligned with regulatory guidance. - Keep your question sets consistent across projects and clients. - Link responses to evidence, tickets and owners. - Generate clean reports for regulators, customers and internal stakeholders.

The goal is not to remove humans from the loop. Instead, automation allows your experts to spend less time on formatting and chasing information, and more time on the judgment calls that really matter.

Practical tips for your next DPIA

  • 1Start early in the project, not two days before launch.
  • 2Involve product, engineering, security and legal in one conversation.
  • 3Use language that people outside your team can understand.
  • 4Record not just answers but also assumptions and uncertainties.
  • 5Treat the DPIA as a living document that can be updated as the system evolves.

Done well, a DPIA is not a burden. It is a chance to design products that respect people's expectations and stand up under regulatory and customer scrutiny.

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