4 steps to execute flawless DPIAs

Data privacy has become a crucial issue in today’s digital day and age, with increased concerns over the collection, storage, and use of personal data.

The General Data Protection Regulation (GDPR) has set guidelines for organizations that process personal data, and one of these guidelines is the Data Protection Impact Assessment (DPIA).

In this blog post, we will discuss what a DPIA is, why it is important, and provide a step-by-step guide on how to conduct an affective DPIA.

What is a DPIA?

A DPIA is an assessment that organizations can use to identify and mitigate data protection risks in their data processing activities. It is required under the GDPR if data processing is likely to result in a high risk to the rights and freedoms of natural persons (GDPR, Article 3).

A DPIA enables organizations to identify potential risks and take steps to mitigate them early on in the process. This can help organizations ensure compliance with the GDPR, enhance data protection and security, and demonstrate to their customers/users that their personal data is being valued and protected.

Moreover, since a DPIA is part of the Data Protection by Design principle, you make sure you incorporate this principle into new projects, mitigating security risks and extra costs.

Every privacy professional knows the struggles of executing a DPIA:

There’s one methodology that will help you execute a DPIA in 4 stages: CNIL DPIA Guidelines.

What is the CNIL?

The CNIL (Commission nationale de l’informatique et des libertés) is a French authority established in 1978 to protect privacy rights, enforce data protection laws, and promote responsible use of personal data. It oversees GDPR implementation in France, provides guidance on data protection, and can investigate complaints and impose fines for violations. The CNIL ensures ethical and responsible use of personal data.

What are the 4 stages of a DPIA?

According to the CNIL, the 4 stages of a DPIA include:

  1. Contextualizing the DPIA
  2. Ensuring proportionality and necessity
  3. Identifying and mitigating risks
  4. Validating your DPIA

Stage 1: Contextualizing the DPIA

The first stage involves presenting a description of the processing, which considers the nature, scope, context, purposes, and stakes:

Stage 2: Ensuring proportionality and necessity

In this stage, you need to assess the necessity and proportionality of the process:

Stage 3: Identifying and mitigating risks

In the third stage, evaluate controls and risks:

Stage 4: Validating your DPIA

In the final stage, it is crucial to organize the findings of your study effectively. 

For example, you should present the selected controls to ensure compliance, data security, an action plan, the advice from the data protection responsible person, and a comprehensive view of the data subjects, in various easy-to-understand formats, such as visual representations.

After assessing the acceptability of the risks involved, the DPIA may be validated, conditionally approved with improvements, or rejected based on the severity and likelihood of potential risks.

Final thoughts and reflections on DPIA

To sum up, a DPIA includes defining the context, assessing controls to guarantee the proportionality and necessity of processing, evaluating risks, and validating the DPIA. However, a DPIA may not always be necessary. For example, if the processing is unlikely to pose a significant risk to the data subjects’ rights or freedoms, or if a similar DPIA has been carried out for processes with similar nature, scope, context, and purposes.

Nevertheless, it is crucial to obtain accurate and timely information for the DPIA and maintain records of previous actions. Remember to continuously review and update the DPIA, and identify the responsible individuals at an early stage.

Based on our experience, we understand that executing a DPIA can be a challenging and time-consuming task.

Therefore, we have developed a DPIA module, integrated with the CNIL framework and other modules, to provide easy access to information through linked items like the Record of Processing Activities (RoPA).

Moreover, RESPONSUM enables you to conduct a pre-DPIA to determine whether a DPIA is required or not. If a DPIA is necessary, don’t worry: With RESPONSUM’s DPIA template you can execute the DPIA four times faster!

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Written by

Yannick Vranckx

Marketing Specialist @ RESPONSUM


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