A Step-by-Step Guide to Conducting Your First DPIA

Before You Begin: Preparation

Before conducting your first DPIA, ensure you have:

• A DPIA template that covers all elements required by Article 35(7)
• Access to the DPO for advisory input
• A clear understanding of the processing activity being assessed
• Identified stakeholders who can provide input on data flows, technical controls, and business objectives

Step 1: Describe the Processing

Document the processing activity in detail:

• Nature: What data is collected? How is it processed, stored, and eventually deleted?
• Scope: How many data subjects are affected? What volume of data is processed? How long is it retained?
• Context: What is the relationship between the organization and the data subjects? What are their reasonable expectations?
• Purpose: Why is this processing necessary? What business objective does it serve?
• Data flows: Create a diagram showing data inputs, processing steps, storage locations, sharing with third parties, and outputs.

Step 2: Assess Necessity and Proportionality

Evaluate whether the processing is necessary and proportionate to its stated purpose:

• Is the data collection limited to what is necessary (data minimization)?
• Could the same purpose be achieved with less data or less invasive methods?
• What is the legal basis for processing (consent, legitimate interest, contract, etc.)?
• How will data subject rights be facilitated (access, rectification, erasure, portability)?

Step 3: Identify Risks

For each processing step, identify potential risks to data subjects:

• Unauthorized access: Could data be accessed by unauthorized parties (external breach, insider threat)?
• Data loss: Could data be accidentally deleted, corrupted, or made unavailable?
• Excessive collection: Could more data be collected than necessary?
• Purpose creep: Could data be used for purposes beyond what was communicated?
• Discrimination: Could processing lead to unfair treatment based on personal characteristics?
• Loss of control: Could data subjects lose control over their personal data?

For each risk, assess likelihood (low, medium, high) and severity (low, medium, high). The combination determines the overall risk level.

Step 4: Define Mitigation Measures

For each identified risk, propose measures to reduce it:

• Technical measures: Encryption, pseudonymization, access controls, audit logging, backup systems.
• Organizational measures: Policies, training, data processing agreements, incident response procedures.
• Contractual measures: Vendor agreements, data sharing agreements, processor obligations.

Re-assess each risk after applying mitigations. The resulting residual risk should be at an acceptable level.

Step 5: Document, Review, and Iterate

Compile the DPIA into a formal document. Have the DPO review and provide their opinion. Present to the decision-maker (typically the data controller or senior management) for sign-off. If residual risks remain high, consider prior consultation with the supervisory authority under Article 36.

Schedule a review date and treat the DPIA as a living document that is updated when the processing changes.

Jerisaliant's DPIA module walks you through each step with guided forms, automated risk scoring, and built-in templates that ensure Article 35(7) compliance.