Think about how much personal information is collected from you every day. You use your fingerprint or Face ID to unlock your phone, provide your details when opening a bank or financial account, share personal information when creating social media accounts, and enter your details whenever you sign up for a new service or make an online purchase.
Some of this information is relatively straightforward, while other forms, such as biometric information, can be more sensitive and carry greater risks if they are collected or used improperly. For organisations, identifying and assessing these potential risks before processing personal data is an important part of responsible data protection.
Organisations have a responsibility to handle that data properly and consider the impact of processing on the people it belongs to (aka “data subjects”). The existence of data protection laws and regulatory frameworks tells us something important: personal data is valuable, and with that value comes responsibility. One of the most effective ways of meeting that responsibility is through a Data Protection Impact Assessment (DPIA).
What Is a DPIA?
A Data Protection Impact Assessment (DPIA) is a process used to identify, assess and minimise the privacy risks associated with processing personal data. Rather than waiting for a problem to occur, a DPIA encourages organisations to think about potential risks before a new project, system or processing activity that deals with large amounts of personal data, or simply a small amount of sensitive data – begins. DPIAs are a proactive approach to privacy that help organisations demonstrate accountability while protecting the rights and freedoms of individuals through a comprehensive privacy risk assessment.
For example, before a school rolls out facial recognition to track student attendance, it needs to conduct a DPIA to consider the risks to children’s data and whether a less intrusive method, like a register, would achieve the same end goal.
Why Is a DPIA Important for Organisations?
The real value of a DPIA is that it catches problems early, when they are easier and less expensive to address. When launched during the planning stages of a project, a DPIA encourages organisations to ask important questions such as:
- Do we need this personal data? If so, why?
- Is collecting this information necessary?
- Is there a less intrusive way to achieve the same objective?
- Are there additional safeguards to deploy pre-launch?
If a standard password and multifactor authentication can adequately secure access to a system, is it necessary to require facial recognition or biometric authentication? These are the types of questions a DPIA is designed to answer.
When Is a DPIA Required?
Under leading international frameworks, including Article 35 of the General Data Protection Regulation (GDPR) and risk assessment guidelines under the California Consumer Privacy Act (CCPA), a DPIA is generally required when data processing is likely to result in a high risk to the rights and freedoms of individuals. Organisations are typically expected to conduct an assessment before launching operations that involve:
- Using automated systems to make major decisions about people, including profiling, where those results have legal or significant impacts on their lives, such as automated tools that reject loan applications or filter job candidates
- Processing large amounts of sensitive personal data, such as health, biometric or religious information, or data relating to criminal convictions and offences
- Carrying out large-scale monitoring of publicly accessible areas, such as through extensive CCTV or other surveillance technologies
What Should a DPIA Include?
A DPIA should do more than document the personal data an organisation intends to collect. It should help the organisation understand whether the proposed processing is justified, what risks it may create for individuals, and what measures are needed to address those risks before the project proceeds.
While the level of detail will depend on the nature and complexity of the processing, a DPIA should generally cover five key areas:
- Description of the processing activity: Identify the personal data involved, the purpose for collecting it, how it will be used and stored, who it may be shared with, and how long it will be retained.
- Necessity and proportionality: Establish whether the processing is necessary to achieve the intended objective and whether that objective could be achieved through a less intrusive approach. For example, could an organisation use keycards to manage employee access instead of collecting employees’ fingerprints?
- Assessment of risks to individuals: Consider the potential harm that could arise from the processing, including unauthorised access, discrimination, identity theft, financial loss or reputational damage. Both the likelihood of harm and its potential severity should inform the assessment.
- Measures to address identified risks: Specify the safeguards needed to reduce those risks. Depending on the circumstances, these may include encryption, access restrictions, data minimisation, defined retention periods, stronger security controls and procedures for responding to data breaches.
- Consultation, accountability and review: Involve relevant stakeholders, including the Data Protection Officer (DPO) or privacy specialist where appropriate. Document the decisions taken, assign responsibility for implementing safeguards and establish how the assessment will be reviewed if the project or its risks change.
A DPIA should not be treated as a form to complete and file away. Its purpose is to inform decisions. If the assessment identifies risks that cannot be adequately addressed, the organisation should reconsider the proposed approach and determine whether further safeguards or changes are necessary before proceeding.
How TAAS Can Help
Conducting a DPIA requires more than identifying the personal data involved. Organisations must also assess the potential impact on individuals, determine whether the processing is necessary and proportionate, and identify safeguards that address the risks without undermining legitimate business objectives.
Through our Data Protection Impact Assessment services, T.A.A.S Cyber Solutions Ltd helps organisations assess privacy risks associated with new projects, systems and processing activities. We support organisations in identifying potential risks, evaluating their implications, recommending appropriate safeguards and documenting the decisions needed to support accountable data processing.
Our approach recognises that effective data protection should not be an afterthought or an obstacle to innovation. A well-conducted DPIA can help organisations identify concerns early, make better-informed decisions and build appropriate privacy safeguards into their operations from the outset.
Whether your organisation is introducing a new technology, expanding how it uses personal data or reviewing an existing processing activity, TAAS can help you assess the risks and determine the measures needed to address them.
Planning a new project that involves personal data? Engage TAAS to conduct a DPIA and help you identify and address privacy risks before they become costly compliance or trust issues. Contact us to discuss your organisation’s needs.