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PIA v. DPIA: What is the Difference Under GDPR?

PIA v. DPIA: What is the Difference Under GDPR?

If your organization needs to meet GPDR requirements, you may find yourself asking this question: “What’s the difference between a PIA and DPIA?”

Privacy Impact Assessments (PIA) and Data Protection Impact Assessments (DPIA) are similar and it can be difficult to tell the difference between the two. In fact, the terms often describe the same type of assessment, because they both operate as an analysis conducted at the beginning of a project’s lifecycle. They are assessments that measure the impact of privacy risk.

However, while both terms may sometimes be used interchangeably, it is important to recognize that they are not the same. Under the GDPR, there are certain triggers that put a PIA or DPIA into play which we will look at here. To dig into the difference between a PIA and DPIA, let’s start by looking at each individually.

What is a Privacy Impact Assessment (PIA)?

Privacy impact assessments are conducted for the establishment of new or improved projects, developments, or undertakings that might result in privacy risks. They are also conducted when processes involving personal information are changed. PIAs are generally performed for the benefit of the project or organization itself rather than strictly for the protection of personal data or data subjects. PIAs help to garner trust and protect the reputation of the organization when handling personal information.

Implementing a new project can be quite the venture, with all kinds of unknown variables that support the project’s goals and objectives. This can include researchers, participants, and technologies all coming together to complete the tasks of the project. 

A privacy impact assessment is a type of assessment that analyses the activities of a project and determines how those activities might propose a risk to the privacy of the project’s participants. In that, the PIA takes into account the personal information collected and processed on individuals and considers whether or not the activities of the project will present a risk to that personal information. The primary goal of a PIA is to minimize and eliminate risks to personal information during its processing. 

Conducting a PIA ensures that privacy is at the forefront of every project or data processing engagement. Doing so also ensures that you are able to change the design of your project, if needed, in order to mitigate risks that come up in the assessment. It is an essential part of your project management when undergoing projects that handle data processing.

What is a Data Protection Impact Assessment (DPIA)?

Data protection impact assessments are performed under the regulations of the GDPR to assess the level of risk to personal information in an undertaking, project, task, or data processing activity. They identify risks of processing data and ways to minimize risk as early in the process as possible. 

DPIAs are only required under the GDPR when processing or the use of new technology is likely to cause a high risk to the rights and freedoms of data subjects. DPIAs are conducted before data processing activities occur. DPIAs analyze the processing of personal information and how personal information will be used. They identify possible risks that might affect personal information and how an organization might mitigate that risk. As with a PIA, a DPIA will help to justify any risks that remain after assessment. 

In addition to ensuring compliance with the GDPR, many benefits come with performing DPIAs. They encourage best practices for data protection at the outset by ensuring data protection by default and by design. They build trust with your company and with the data subjects by ensuring transparency of processing. They help build awareness of data protection and privacy issues across the organization and have the ultimate benefit of minimizing risk. 

When Should a DPIA be Conducted?

As noted above, you must conduct data protection impact assessments if data processing is likely to result in a high risk to the rights and freedoms of data subjects. DPIAs must also be conducted before any data processing activities occur. Be sure to complete DPIAs before implementing new technologies for processing or undertaking any project that entails profiling or that includes processing of personal data at a mass scale. Implementing data protection by design and default in this process would mean carrying out the DPIA as early as possible in the project scope. 

What Should be Included in a DPIA?

A DPIA should describe the project or undertaking and the purpose for processing personal information as it relates to the project. The DPIA should explain these in relation and as much detail as possible. It should also describe why the DPIA is necessary and its scope. For example, suggesting the DPIA itself enhances privacy awareness and risk management through its function. 

The DPIA should assess the necessity of processing personal information for the undertaking and ensure that you only collect the personal data that is necessary for the tasks involved. This is called assessing necessity and proportionality

Next and most importantly, the DPIA should include an assessment of risks by cataloging relevant risks and high risks that are likely to impact individuals. Risks presented might include events anticipated to occur during the project.

The purpose of this is to initiate the next phase of the DPIA, which is the strategies for mitigation of risk to the data subject. This is also to ensure that no further risks impact individuals or affect the implementation of the project or new technologies. You should include measures for safeguarding personal data and adhering to GDPR compliance in this step of the DPIA. 

You conclude your DPIA by weighing the perceived risk against the remediation strategy and producing the assessment results. 

Overall, DPIAs help you to defend against disaster proactively. If you haven’t successfully mitigated the risks associated, you must contact the supervisory authority for further advice. 

Getting GDPR Compliant with Carbide

Understanding when and how to use a PIA or DPIA is important for meeting GDPR requirements for your business. The Carbide platform helps your business achieve compliance with the GDPR and other industry standards by providing custom auto-generated policies, controls, and action items with a team of security experts to help you maintain a robust information security program. Talk with us to learn how we can help you get GDPR compliant.