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Dpia Risk Assessment

Dpia Risk Assessment Template for Ireland

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Key Requirements PROMPT example:

Dpia Risk Assessment

"I need a DPIA Risk Assessment for our new AI-powered customer behavior analysis system that will process data of Irish customers, to be launched in March 2025; the assessment should focus on automated decision-making risks and cross-border data transfers to our US-based cloud servers."

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Document background
The DPIA Risk Assessment is a mandatory requirement under Article 35 of GDPR and Irish data protection law for processing activities likely to result in high risks to individuals' rights and freedoms. This document should be used whenever an organization plans to implement new high-risk processing activities, significant changes to existing processing, or when handling sensitive personal data at scale. The assessment must be conducted prior to the processing and should be regularly reviewed and updated. It requires input from various stakeholders and must follow the Irish Data Protection Commission's guidance on DPIAs. The document helps organizations identify and minimize data protection risks, demonstrate compliance, and determine whether consultation with the supervisory authority is necessary.
Suggested Sections

1. Document Control: Version history, approval status, and document owners

2. Executive Summary: Brief overview of the DPIA, key findings, and recommendations

3. Project Overview: Description of the processing activity, its context, and business objectives

4. Data Processing Description: Detailed information about personal data processing, including data types, purposes, and data flows

5. Necessity and Proportionality Assessment: Analysis of whether the processing is necessary and proportionate to the objectives

6. Risk Assessment: Identification and evaluation of privacy risks to individuals' rights and freedoms

7. Risk Mitigation Measures: Description of measures to address identified risks and ensure GDPR compliance

8. DPO Review and Recommendations: Data Protection Officer's assessment and additional recommendations

9. Conclusion and Sign-off: Final determination on whether processing can proceed and approval signatures

Optional Sections

1. Prior Consultation Requirements: Section required when the residual risk remains high and consultation with the DPC is necessary

2. Cross-border Processing Assessment: Required when processing involves data transfers outside the EEA

3. Processor Due Diligence: Include when third-party processors are involved in the processing activities

4. Special Category Data Considerations: Required when processing special category data under Article 9 GDPR

5. Children's Data Processing: Required when processing involves personal data of children under 18

6. Legacy Systems Integration: Include when the processing involves integration with existing legacy systems

Suggested Schedules

1. Data Flow Diagrams: Visual representations of how personal data flows through the system

2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrices

3. Technical Security Measures: Detailed description of security controls and measures implemented

4. Stakeholder Consultation Records: Documentation of consultations with stakeholders and affected parties

5. Compliance Checklist: Detailed checklist against GDPR requirements and Irish DPC guidance

6. Data Retention Schedule: Details of retention periods for different categories of personal data

7. Third Party Processors List: List of all data processors involved and their roles

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
Personal Data
Special Categories of Personal Data
Processing
Data Controller
Data Processor
Data Subject
Data Protection Impact Assessment
Risk
High Risk Processing
Data Protection Officer
Supervisory Authority
Irish Data Protection Commission
Cross-border Processing
Privacy by Design
Privacy by Default
Data Protection Law
GDPR
Pseudonymisation
Data Minimisation
Purpose Limitation
Storage Limitation
Data Subject Rights
Prior Consultation
Technical Measures
Organisational Measures
Impact Assessment
Risk Matrix
Likelihood
Severity
Residual Risk
Mitigation Measures
Data Flow
Processing Operations
Third Party
Recipient
Data Transfer
Appropriate Safeguards
Legitimate Interest
Legal Basis
Consent
Privacy Notice
Data Breach
Record of Processing Activities
Data Retention Period
Information Security Incident
Privacy Risk
Clauses
Data Processing Description
Lawful Basis for Processing
Data Protection Principles
Privacy Risk Assessment
Security Measures
Data Subject Rights
Cross-border Transfers
Consultation Requirements
Documentation and Record Keeping
Governance and Oversight
Impact Assessment
Risk Mitigation
Technical Controls
Organizational Controls
Compliance Monitoring
Data Retention
Data Minimization
Special Category Data Handling
Third Party Processing
International Data Transfers
Data Breach Response
Training and Awareness
Review and Updates
Accountability Measures
Relevant Industries

Financial Services

Healthcare

Technology

Education

Public Sector

Telecommunications

Insurance

E-commerce

Professional Services

Research and Development

Manufacturing

Transport and Logistics

Relevant Teams

Legal

Information Security

Data Protection

Risk & Compliance

IT

Project Management Office

Information Governance

Technical Architecture

Operations

Internal Audit

Relevant Roles

Data Protection Officer

Privacy Manager

Information Security Manager

Risk & Compliance Officer

IT Director

Legal Counsel

Project Manager

Systems Architect

Chief Information Security Officer

Privacy Analyst

Compliance Manager

Chief Technology Officer

Business Analyst

Information Governance Manager

Industries
General Data Protection Regulation (GDPR): The fundamental EU regulation governing data protection and privacy, which requires DPIAs for high-risk processing activities (Article 35)
Irish Data Protection Act 2018: The national legislation implementing GDPR in Ireland, providing specific requirements for data protection and DPIAs in the Irish context
Law Enforcement Directive (LED): EU Directive 2016/680 which may be relevant if the DPIA involves processing personal data for law enforcement purposes
ePrivacy Regulations 2011 (S.I. No. 336/2011): Irish regulations implementing the EU ePrivacy Directive, relevant if the DPIA involves electronic communications or cookies
Irish Data Protection Commission (DPC) Guidelines: Official guidance from the Irish DPC on conducting DPIAs, including specific requirements and thresholds for when a DPIA is mandatory
Article 29 Working Party Guidelines on DPIA: EU-level guidelines (now endorsed by the European Data Protection Board) providing criteria for determining whether processing is likely to result in high risk
European Data Protection Board Guidelines: Current EU-level guidance on DPIAs and related data protection matters, which must be considered in the Irish context
Freedom of Information Act 2014: May be relevant if the DPIA involves public bodies or the processing of information that could be subject to FOI requests
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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