Whether you’re kicking off a major project or making changes to an existing one that uses personal data, performing a Data Protection Impact Assessment (DPIA) helps you ensure processes and outcomes comply with the General Data Protection Regulation (GDPR).
What’s a DPIA?
If DPIA is a new term for you, don’t worry – you’re not the only one. At its core, a DPIA helps an organization analyze any high-risk data management process to identify and minimize threats. This includes both compliance risks as well as broader dangers that can harm the social or economic freedoms of an individual.
DPIAs are a tool you can use to organize processes and ensure specific project outcomes that align with GDPR and your data privacy plans. While they’re intended to assess potential risks in terms of likelihood and severity, these processes don’t have to eradicate 100% of them – however, it should help you document each risk and explain why those that remain are justified.
While every business – and therefore DPIA – is unique, there are seven universal steps your process needs to take to ensure consumer data privacy and security:
Step One: Identify Your Needs
Consider your initial project proposal – what does the effort aim to achieve? What type of data processing will it involve? These are important questions to ask not only to maximize your DPIA’s impact, but to avoid unnecessary, costly, and potentially dangerous data collection efforts.
Your first step should also include a summary of why your organization identified a need for a DPIA in the first place. That way, everyone involved in the project understands how important successful performance is.
Step Two: Describe Your Data
What type of information does your data processing project include? After determining why a DPIA is necessary, your organization needs to determine how to process data – and what it considers valuable.
Think about how you will collect, use, store, and delete information to maximize security and ensure GDPR compliance throughout the DPIA process. Know your data sources, who you’re sharing information with, and precisely how your data flows to identify which tasks put your organization at the highest risk.
Beyond the security of your DPIA effort, you also need to dig into the nature of the data collected. What’s the scope, context, and purpose of your processing? Are you collecting specially categorized information governed by extra-stringent standards under GDPR? An expensive fine or highly publicized courtroom hearing shouldn’t be the way you learn these insights.
Step Three: Consult Your Experts
Once you understand the data involved in DPIA activities, you need to have a plan for when, how, and if you seek individuals’ expertise. Which departments and decision-makers need to be involved in the project? Do you need to bring in outside help to ensure success?
Without the right mix of experience, a DPIA can be difficult to drive forward. It’s critical your project identifies the people power and support it needs before issues arise to guarantee lasting, impactful business results.
Step Four: Assess Your Legal Status
Are you legally in the clear where data is concerned? The GDPR places new restrictions on how companies can use consumer data, so you need to be sure processing satisfies the purpose it was created for.
In addition to your legality, your DPIA also needs to consider how data management initiatives support individual consumer rights – what measures are you taking to ensure processors and partners comply with GDPR? How do you protect information at-rest and in-motion?
Step Five: Identify Your Risks
After assessing your organization’s GDPR compliance, the next step of your DPIA should focus on any potential vulnerabilities data processing contains – especially if you collect information from children or other vulnerable groups as defined by law.
Are there inherent risks or flaws associated with your data processing methodology? Do you have additional standards to uphold outside of legal requirements – like a code of conduction or industry certification, for example? Any relevant threat, concern, or widespread trend should be included to eliminate risk and potential damages down the line.
Step Six: Reduce Your Risks
For any moderate or likely risks identified in the previous step, your DPIA should feature practical and effective measures to counter their negative consequences – if not avoid them entirely – in step six.
This includes understanding each risk’s real-world business impact, addressing residual risks not remedied by these measures, and tracking approvals to ensure visibility and understanding of where data protection progress still needs to be made.
Step Seven: Record Your Outcomes
It’s not enough to simply experience outcomes – your organization needs to measure and record them to decide whether or not a DPIA ultimately helped your project achieve its intended results. Additionally, this gives your Data Protection Officer a summary of the entire seven-step process to determine potential next steps and identify areas of improvement where GDPR compliance is concerned.
Speaking of steps, a DPIA is only one small part of your GDPR-compliant data protection initiative. Purchase your Performance FirstSM Pocket Guide: GDPR Compliance Toolkit today to ensure comprehensive data privacy and security moving forward!