The Data Protection Impact Assessment (DPIA) is a mandatory requirement under Article 35 of the GDPR and Dutch privacy law for processing activities likely to result in high risks to individuals' rights and freedoms. This document becomes necessary when an organization implements new technologies, processes sensitive data at scale, or conducts systematic monitoring of public areas or individuals. The DPIA must be conducted prior to the processing and requires regular updates when there are changes to the risk level of processing activities. In the Netherlands, the Autoriteit Persoonsgegevens has published a list of processing operations that require mandatory DPIAs, and this document ensures compliance with both EU-wide and specific Dutch requirements. The assessment helps organizations implement privacy by design, demonstrate accountability, and maintain compliance with data protection regulations.
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1. Document Control: Version history, approval status, and review dates of the DPIA
2. Executive Summary: Overview of the assessment, key findings, and main recommendations
3. Project Description: Details of the data processing activity being assessed, including purpose and context
4. Data Processing Overview: Detailed description of personal data types, processing purposes, and data flows
5. Necessity and Proportionality Assessment: Analysis of whether the processing is necessary and proportionate to its purposes
6. Legal Basis and Compliance: Assessment of legal grounds for processing and compliance with GDPR principles
7. Risk Assessment: Identification and evaluation of privacy risks to individuals
8. Risk Mitigation Measures: Proposed controls and measures to address identified risks
9. DPO Consultation: Input and recommendations from the Data Protection Officer
10. Conclusions and Sign-off: Final determination of residual risks and approval decisions
1. Cross-border Transfer Assessment: Required when processing involves data transfers outside the EU/EEA
2. Special Category Data Analysis: Needed when processing sensitive personal data categories
3. Technical Security Assessment: Detailed IT security evaluation for complex technical processing
4. Processor Due Diligence: Assessment of third-party processors when relevant
5. Industry-Specific Compliance: Additional requirements for regulated sectors (healthcare, financial services, etc.)
6. AI/Automated Decision-Making Assessment: Required when processing involves AI or automated decision-making
7. Prior Consultation Documentation: Required if supervisory authority consultation is necessary
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. Processing Records: Detailed inventory of processing activities
4. Security Controls Documentation: Technical and organizational security measures
5. Stakeholder Consultation Results: Summary of consultations with affected parties
6. Privacy Notice Templates: Draft privacy notices related to the processing
7. Technical Specifications: Relevant system architectures and technical documentation
8. Action Plan: Detailed implementation plan for recommended measures
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