A Data Protection Impact Assessment (DPIA) is a structured evaluation of how and why personal data is processed within a specific system, project, or workflow. It’s not just a bureaucratic exercise, it’s a legal requirement under the General Data Protection Regulation (GDPR) and a strategic tool for embedding privacy into the design of new technologies and processes.
At the heart of the DPIA obligation lies Article 35 of the GDPR, which outlines when a DPIA must be conducted and what it must contain. The law requires organizations to carry out a DPIA when a processing activity is “likely to result in a high risk to the rights and freedoms of natural persons.” This includes, but is not limited to, deploying new technologies, large-scale profiling, systematic monitoring, or processing sensitive data.
When Is a DPIA Required?
Imagine your HR department is implementing an AI tool to screen CVs, or your customer support team is rolling out a speech-to-text system to analyse conversations. These systems rely on personal data and may introduce risks such as bias, discrimination, or surveillance. In such cases, a DPIA helps you assess whether the processing is lawful, necessary, and proportionate and whether the risks to individuals are adequately mitigated.
Other common scenarios include:
- Deploying a whistleblower platform
- Implementing a conflict-of-interest policy that involves personal disclosures
- Introducing employee monitoring tools or geolocation tracking
- Using biometric authentication or facial recognition
To support organizations in determining when a DPIA is required, Data Protection Authorities (DPAs) publish lists of processing operations that typically do require a DPIA (blacklists) and those that do not (whitelists). These lists vary across jurisdictions but offer valuable insight into national regulatory expectations. In addition to national guidance, organizations should also consult the European Data Protection Board (EDPB) guidelines, which provide harmonized interpretation and practical recommendations across the EU.
What Does a DPIA Include?
The GDPR sets out minimum content requirements for a DPIA, including:
- A description of the processing and its purposes
- An assessment of necessity and proportionality
- An evaluation of risks to data subjects
- Measures to mitigate those risks
Many DPAs provide templates to help organizations structure their DPIAs effectively. Crucially, the Data Protection Officer (DPO) must be involved in the process. Their role is to advise on risk, ensure compliance, and help the organization document its accountability.
You can read more about the important role of the DPO in our blog article Why Every Organisation Needs a Data Protection Officer.
DPIA as a Privacy-by-Design Tool
Conducting a DPIA early in the project lifecycle supports the principle of privacy by design, the obligation to integrate data protection from the outset, not as an afterthought. This proactive approach helps prevent costly redesigns, reputational damage, and regulatory sanctions.
Moreover, the DPIA is a key accountability mechanism. It demonstrates that the organization has considered privacy impacts, consulted relevant stakeholders, and taken steps to protect individuals’ rights. It also reinforces the legal obligation of data processors to assist controllers in conducting DPIAs when their services are involved.
Final Outcome: Risk Classification and Mitigation
The result of a DPIA should be a clear classification of the risk level (e.g. low, moderate, high) and a set of mitigation measures. These might include technical safeguards (e.g. pseudonymization, access controls), organizational policies (e.g. training, retention limits), or changes to the processing itself.
If your organization is navigating complex environments, such as AI deployment, cross-border data flows, or sensitive employee data, our team can support you throughout the DPIA lifecycle. From scoping and stakeholder engagement to documentation and regulator-facing summaries, we help ensure your DPIAs are not only compliant, but meaningful.