Privacy Impact Assessment: Step-by-Step Template

What Is a Privacy Impact Assessment?

A Privacy Impact Assessment (PIA), sometimes called a Data Protection Impact Assessment (DPIA) under GDPR, is a structured process for identifying, evaluating, and mitigating privacy risks associated with data processing activities. PIAs help you find and fix privacy problems early, before they result in harm to individuals or regulatory penalties.

Under GDPR Article 35, DPIAs are mandatory when processing is likely to result in high risk to individuals' rights. Even where not legally required, conducting PIAs is considered best practice.

When to Conduct a PIA

Trigger a PIA whenever you are:

• Launching a new product or service that processes personal data
• Implementing new technology, such as biometrics, AI, or IoT devices
• Changing how existing personal data is collected, used, or shared
• Processing sensitive or special category data at scale
• Engaging in systematic monitoring of individuals

The earlier in the project lifecycle you begin, the easier and less costly it is to address identified risks.

Step 1: Describe the Processing

Document the processing activity in detail:

• What personal data is collected and from whom?
• What is the purpose and lawful basis?
• How is the data collected, stored, and transmitted?
• Who has access, including third parties?
• How long is data retained and how is it disposed of?

Step 2: Assess Necessity and Proportionality

Evaluate whether the processing is necessary and proportionate:

• Is all collected data actually needed for the purpose?
• Could the purpose be achieved with less data or anonymised data?
• Are retention periods justified?

Document your reasoning and redesign the processing if it collects more data than necessary.

Step 3: Identify Privacy Risks

Systematically identify risks to individuals. Consider:

• Unauthorised access or disclosure of personal data
• Loss or destruction of data
• Inaccurate data leading to incorrect decisions
• Excessive data collection or function creep
• Lack of transparency about data use
• Difficulty for individuals to exercise their rights

For each risk, assess likelihood and severity of impact.

Step 4: Define Mitigation Measures

For each identified risk, determine appropriate measures:

• Technical measures: encryption, access controls, pseudonymisation, data minimisation
• Organisational measures: policies, training, access reviews, contractual protections
• Process measures: consent management, data subject request workflows, retention schedules

Ensure each measure is specific, actionable, and assigned to a responsible owner.

Step 5: Document and Approve

Compile the PIA into a formal document including the processing description, necessity assessment, risk register with ratings, mitigation measures with ownership and timelines, and approval signatures from the project owner and DPO.

Step 6: Monitor and Review

Review and update the PIA when the processing activity changes, new risks are identified, a relevant breach occurs, or regulatory guidance changes. Integrate PIA reviews into your project change management process.

A well-executed PIA protects individuals, reduces regulatory risk, and builds trust with customers and partners. It is one of the most practical tools in any privacy professional's toolkit.