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.
What Is a DPIA?
A Data Protection Impact Assessment (DPIA) is a structured process that helps organisations identify and mitigate privacy risks before launching a new processing activity, product feature, or system change. It is a core requirement under GDPR Article 35.
When Is a DPIA Legally Required?
A DPIA is mandatory when processing is likely to result in high risk to individuals. Common triggers include:
- Systematic and extensive profiling that produces legal or similarly significant effects
- Large-scale processing of special category data (health, biometric, criminal records)
- Systematic monitoring of publicly accessible areas (e.g. CCTV, location tracking)
- Processing children data at scale
- Deploying new technologies with unclear privacy implications
The Four Core Sections of a DPIA
- Description of processing — what data, for what purpose, with what legal basis
- Necessity and proportionality — is this the least invasive way to achieve the goal?
- Risk assessment — likelihood and severity of risks to data subjects
- Mitigation measures — controls that reduce identified risks to acceptable levels
Who Owns the DPIA?
The data controller is responsible. In practice, the DPO advises, product/engineering identifies risks, and legal reviews the final document. The DPO must be consulted where required.
What Happens After a DPIA?
If residual risk remains high after mitigation, you must consult your supervisory authority before proceeding. The DPIA must be kept and updated whenever the processing changes materially.
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