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GRC glossary / GDPR

Data Protection Impact Assessment (DPIA)

A risk assessment of processing operations for the rights and freedoms of individuals. Required under Art. 35 GDPR when processing is likely to result in high risk.

A DPIA is required whenever processing is likely to result in a high risk to individuals. The practical test is the 10 criteria set out by the EDPB (WP248): profiling, large-scale processing, sensitive data, monitoring of publicly accessible areas, and several others. The rule of thumb is: two or more criteria means you carry out a DPIA.

In Poland an additional list issued by the Polish DPA (M.P. 2019 item 666) specifies types of processing that require a DPIA by default. These are two separate tests running in parallel; meeting either one of them is sufficient to trigger the obligation.

A DPIA is a process with a decision and a residual risk outcome, not a form to file away in a drawer. If the risk remains high after all mitigating measures have been applied, you consult the Polish DPA before starting the processing. A well-executed DPIA inherits data directly from the record of processing activities rather than duplicating it from scratch.

In practice: see the relevant RealSec module.

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