What should an impact assessment include? 

A Data Privacy Impact Assessment (DPIA) can help organizations ensure they cover the necessary aspects when assessing the potential risks and impacts associated with their data processing activities. A data impact assessment should include the following components: 

Identify the Data Processing Activity:

• Describe the purpose of the data processing activity.
• Identify the types of personal data collected, stored, or processed.
• Determine the source of the personal data.

Assess the Legal and Regulatory Requirements:

• Identify the applicable data protection laws and regulations.
• Ensure compliance with data protection principles and requirements.
• Consider any specific requirements for sensitive or special categories of personal data.

Evaluate the Data Protection Risks:

• Identify potential risks that may arise from the data processing activity. 
• Assess the likelihood and severity of each risk.
• Consider risks related to data breaches, unauthorized access, data loss, or inaccuracy.

Analyze the Impact on Individuals’ Privacy and Data Protection Rights:

• Consider the potential impact on individuals’ privacy and data protection rights.
• Evaluate risks of discrimination, reputational damage, unauthorized profiling, or other negative consequences.

Assess Data Security Measures:

• Evaluate the adequacy of technical and organizational security measures in place.
• Consider the measures to protect against unauthorized access, accidental loss, or destruction of data.
• Assess the effectiveness of encryption, access controls, authentication mechanisms, and data backup procedures.

Identify Mitigation Strategies:

• Determine measures to mitigate identified risks and ensure compliance.
• Develop strategies to minimize the potential impact on individuals’ privacy.
• Consider implementing Privacy by Design principles and incorporating privacy-enhancing technologies.

Involve Stakeholders:

• Consult with internal teams, data protection officers, or legal advisors.
• Involve individuals or representative organizations when appropriate.
• Seek external expertise if needed, especially for complex or high-risk processing activities.

Document and Review:

• Document the DPIA process, including findings, measures, and decisions taken.
• Maintain records to demonstrate compliance with data protection regulations.
• Regularly review and update the DPIA, especially when there are significant changes in the data processing activity or associated risks.