DPIA and Privacy Risk Assessment are important for protecting personal information. While these two are prominent exercises, there are definite objectives to be set forth as well. In this blog, I am trying to explore the objectives and also the key differences between these two.
Data Protection Impact Assessment (DPIA):
1) DPIA focuses on identifying the impact on data subjects while performing a data processing activity.
2) DPIA considers the rights, freedoms, and safety of an individual (data subject).
3) Unlike a risk assessment or privacy assessment, DPIA is done specifically for a project or processing activity before it starts.
From a GDPR context, DPIA is mandatory for processing activities that have a high risk to the rights and freedoms of individuals (data subjects).
Privacy Risk Assessment:
1) Privacy risk assessment generally focuses on the privacy risks to the organization or a business unit/process from a broader perspective (most of the time, the organization as a whole).
2) Privacy risk assessment is often done in conjunction with a security risk assessment to identify and mitigate security and privacy risks. (It is not mandatory to do the privacy risk assessment along with the security risk assessment, but doing this together will help to identify the risks and dependencies as well.)
Privacy risk assessment is not explicitly mandated by GDPR but can be considered a best practice.
Best Practices for Conducting DPIA and Privacy Risk Assessment:
1) Engaging Stakeholders
Always engage relevant stakeholders like business units, IT, and other relevant teams. This will help to identify the risks effectively.
This is because, as business owners, they have a better idea of the assets, personal information, and their lifecycle.
2) Set the Expectations
As I have mentioned earlier, whether performing a DPIA or risk assessment, the objectives should be clear. DPIA should be data subject-focused, and risk assessment should be business-focused.
3) Continuous Process
DPIA and Risk Assessment should be continuous processes. They should not be limited to a one-time or annual activity.
For instance, if you have a change in the processing activity, ensure that you revisit the DPIA.
Ensure that this doesn’t translate into a mere ritual.
4) Keep it Simple
As far as possible, keep both processes simple. Try to avoid jargon; most of the time, this is one of the reasons why other stakeholders stay away from these processes, as we try to scare them.
Always remember that the objective of DPIA or risk assessment is not to demonstrate the knowledge of the Security or Privacy team. Instead, it should be a process where we engage all the relevant stakeholders and identify the impact and risks.
DPIA and Privacy Risk Assessment have distinct purposes. DPIA focuses on the impact on the data subject, while risk assessment focuses on the business.
Both these processes will help us ensure compliance and foster customer trust.
