The Data Protection Risk Assessment is a mandatory requirement under the Philippines Data Privacy Act of 2012 for organizations processing personal information. This document is required when implementing new systems, processes, or significant changes that involve personal data processing. It helps organizations identify and mitigate privacy risks, ensure compliance with Philippine privacy laws, and demonstrate accountability to the National Privacy Commission. The assessment must be conducted periodically or when there are significant changes to data processing activities, making it a crucial tool for ongoing privacy compliance and risk management.
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1. Executive Summary: High-level overview of the assessment findings, key risks identified, and major recommendations
2. Scope and Objectives: Definition of the assessment scope, including systems, processes, and data types being evaluated
3. Description of Processing Activities: Detailed inventory of personal data processing activities, including purpose, nature, and scope of processing
4. Legal Basis and Compliance Requirements: Analysis of applicable legal requirements under the Data Privacy Act and other relevant regulations
5. Data Flow Analysis: Mapping of how personal data flows through the organization, including collection, processing, storage, and disposal
6. Risk Assessment Methodology: Description of the approach and criteria used to identify and evaluate privacy risks
7. Risk Identification and Analysis: Detailed analysis of identified risks, their likelihood, and potential impact on data subjects
8. Current Controls Assessment: Evaluation of existing technical and organizational measures for data protection
9. Gap Analysis: Identification of areas where current controls fall short of requirements or best practices
10. Recommendations and Action Plan: Proposed measures to address identified risks and gaps, including timeline and responsibilities
1. International Data Transfers: Assessment of cross-border data transfers and associated risks (include when international data transfers are involved)
2. Vendor Assessment: Evaluation of third-party service providers' data protection practices (include when external processors are used)
3. Special Categories of Data: Specific assessment for sensitive personal information (include when processing sensitive personal data)
4. Business Continuity and Disaster Recovery: Assessment of data protection measures in BC/DR plans (include for critical systems)
5. Privacy by Design Assessment: Evaluation of privacy considerations in system design (include for new systems or major changes)
1. Data Inventory Matrix: Detailed listing of all personal data elements processed, including classification and retention periods
2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrix with specific scenarios and impact levels
3. Control Framework Checklist: Comprehensive checklist of technical and organizational measures evaluated
4. Data Flow Diagrams: Visual representations of data flows within and outside the organization
5. Action Plan Timeline: Detailed timeline for implementing recommended controls and improvements
6. Compliance Documentation: Copies of relevant policies, procedures, and compliance certificates
7. Interview and Assessment Records: Documentation of stakeholder interviews and assessment activities conducted
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