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Data Protection Impact Assessment Policy

Data Protection Impact Assessment Policy Template for Ireland

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Key Requirements PROMPT example:

Data Protection Impact Assessment Policy

"I need a Data Protection Impact Assessment Policy for a multinational technology company based in Ireland, with specific focus on AI and machine learning processes, international data transfers, and cloud storage solutions, to be implemented by March 2025."

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Document background
The Data Protection Impact Assessment Policy is designed to ensure organizations comply with Article 35 of the GDPR and Irish data protection requirements when processing personal data that may result in high risks to individuals' rights and freedoms. This document becomes necessary when organizations engage in systematic monitoring, large-scale processing of sensitive data, or innovative use of new technologies. The policy provides comprehensive guidance on conducting DPIAs, including risk assessment methodologies, stakeholder consultation requirements, and documentation procedures. It is particularly relevant for organizations operating in Ireland, considering both the requirements of the Irish Data Protection Commission and the broader EU regulatory framework. The policy must be regularly reviewed and updated to reflect changes in data protection law, regulatory guidance, and emerging best practices.
Suggested Sections

1. Purpose and Scope: Defines the purpose of the policy and its scope of application within the organization

2. Definitions: Key terms used throughout the policy, including technical and legal terminology

3. Legal Framework and Compliance Requirements: Overview of relevant legislation and regulatory requirements

4. Roles and Responsibilities: Defines who is responsible for conducting, reviewing, and approving DPIAs

5. DPIA Triggers and Threshold Assessment: Criteria for determining when a DPIA is required

6. DPIA Process and Methodology: Step-by-step guidance on how to conduct a DPIA

7. Risk Assessment Framework: Methodology for assessing and scoring privacy risks

8. Consultation Requirements: Guidelines for internal and external stakeholder consultation

9. Documentation and Record Keeping: Requirements for maintaining DPIA records and evidence

10. Review and Monitoring: Procedures for ongoing monitoring and periodic review of completed DPIAs

11. Non-Compliance and Enforcement: Consequences of non-compliance and enforcement measures

Optional Sections

1. International Data Transfers: Additional requirements for DPIAs involving international data transfers, particularly relevant for multinational organizations

2. Sector-Specific Requirements: Additional requirements for specific sectors such as healthcare, financial services, or public sector

3. Technology-Specific Considerations: Specific guidance for new or high-risk technologies such as AI, biometrics, or IoT

4. Emergency DPIA Procedures: Expedited DPIA procedures for emergency situations or time-critical processing

5. Data Protection Officer Integration: Specific procedures for organizations with a designated DPO

6. Vendor and Third-Party Assessments: Additional guidance for assessing data processors and third-party risks

Suggested Schedules

1. DPIA Screening Questionnaire: Template questionnaire to determine if a DPIA is required

2. DPIA Template: Standard template for conducting DPIAs

3. Risk Assessment Matrix: Template for scoring and evaluating privacy risks

4. Stakeholder Consultation Template: Template for documenting stakeholder consultations

5. DPIA Review Checklist: Checklist for reviewing completed DPIAs

6. Data Flow Mapping Template: Template for mapping data flows as part of the DPIA process

7. Sample Mitigation Measures: List of common risk mitigation measures and controls

8. DPIA Register Template: Template for maintaining a register of all DPIAs

9. Prior Consultation Form: Template for DPC consultation when required

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Data Protection Impact Assessment (DPIA)
Personal Data
Special Categories of Personal Data
Data Controller
Data Processor
Data Protection Officer (DPO)
High Risk Processing
Data Subject
Processing
Supervisory Authority
Irish Data Protection Commission
Privacy by Design
Privacy by Default
Risk Assessment
Mitigation Measures
Prior Consultation
Data Protection Law
GDPR
Systematic Monitoring
Large Scale Processing
Innovative Technologies
Cross-border Processing
Data Protection Act 2018
Data Flow Mapping
Impact Assessment
Residual Risk
Inherent Risk
Risk Matrix
Threshold Assessment
Data Minimization
Purpose Limitation
Storage Limitation
Processing Operations
Joint Controller
Third Party
Recipient
Data Transfer
Privacy Risk
Consultation Requirements
Stakeholders
Appropriate Technical Measures
Appropriate Organizational Measures
Data Protection Principles
Legitimate Interest
Legal Basis
Automated Decision Making
Profiling
Record of Processing Activities
Privacy Notice
Data Breach
Consent
Accountability
Transparency
Relevant Industries

Technology and Software

Healthcare and Medical Services

Financial Services

Education

Public Sector

Telecommunications

Retail and E-commerce

Professional Services

Insurance

Research and Development

Manufacturing

Transportation and Logistics

Relevant Teams

Legal

Compliance

Information Security

Risk Management

IT

Human Resources

Data Protection

Information Governance

Internal Audit

Project Management Office

Research and Development

Operations

Privacy

Relevant Roles

Data Protection Officer

Privacy Manager

Compliance Officer

Risk Manager

Information Security Manager

Legal Counsel

Chief Information Security Officer

Project Manager

Business Analyst

System Administrator

HR Director

Chief Technology Officer

Data Protection Specialist

Audit Manager

Chief Privacy Officer

Information Governance Manager

Industries
General Data Protection Regulation (GDPR): The fundamental EU regulation on data protection and privacy, which mandates DPIAs for high-risk processing activities and sets out the basic requirements for assessment
Irish Data Protection Act 2018: The national legislation implementing GDPR in Ireland, providing specific local requirements and enforcement mechanisms for data protection
Guidelines on Data Protection Impact Assessment (WP248): European Data Protection Board guidelines specifying when a DPIA is required and how it should be conducted
Irish DPC Guidance on DPIAs: Specific guidance from the Irish Data Protection Commission on conducting DPIAs in the Irish context
ePrivacy Regulations 2011 (S.I. No. 336/2011): Irish regulations concerning privacy in electronic communications, which may need to be considered in DPIAs involving electronic data processing
EU Standard Contractual Clauses (SCCs): Relevant for DPIAs involving international data transfers, particularly important given Ireland's role as an international business hub
NIS Directive (Network and Information Systems): EU directive on cybersecurity that may need to be considered in DPIAs involving critical infrastructure or essential services
Article 29 Working Party Guidelines: Provides additional guidance on data protection impact assessments and high-risk processing activities
Data Protection Act 2018 (Section 36(2)) (Health Research) Regulations 2018: Specific regulations for health research data processing, requiring consideration in DPIAs involving health data
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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