Steps to Conduct a DPIA
Identification of the Processing Activity: The first step is to clearly define the scope and purpose of the data processing activity. Identify the data controller, data processor, and the specific data subjects affected.
Assessment of Necessity and Proportionality: Evaluate whether the data processing is necessary to achieve its intended purpose and if it is proportionate to that purpose. Consider whether there are less intrusive means to achieve the same objective.
Risk Assessment: Identify and assess potential risks to individuals' rights and freedoms. This includes considering the likelihood and severity of these risks, such as unauthorised access, data breaches, or discrimination.
Consultation: If the DPIA reveals that the processing is likely to result in a high risk that the organisation cannot mitigate, consult with the relevant data protection authority for guidance.
Risk Mitigation: Develop a plan to mitigate identified risks. This may include implementing security measures, data protection safeguards, or changes in the data processing process to minimise risks.
Documentation: Maintain a comprehensive record of the DPIA process, including the assessment, results, risk mitigation measures, and any consultation with authorities.
Review and Update: Regularly review and update DPIAs, especially when there are significant changes in data processing activities or if new risks emerge. DPIAs should be a dynamic process, not a one-time assessment.
Publishing Results: In certain cases, it may be necessary to publish the results of the DPIA, especially when the processing activity affects a large number of individuals.
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