Data protection impact assessment
Description
A DPIA must be conducted when processing is likely to result in high risk to data subjects.
⚠️ Risk Impact
High-risk processing without DPIA assessment violates GDPR requirements.
🔧 Remediation
Conduct DPIAs for new processing activities. Use EchelonGraph compliance scoring to assess risk levels.
💀 Real-World Attack Scenario
A tech company launched an AI-powered employee monitoring tool in the EU without conducting a DPIA. The tool tracked keystrokes, screen activity, and email content. A whistleblower complaint to the DPA revealed no DPIA had been performed. The DPA ordered immediate cessation of processing and imposed a €3.4M fine.
💰 Cost of Non-Compliance
Clearview AI 2022: €20M fine in multiple EU countries for high-risk processing without DPIA. Average Art 35 violation fine: €2.5M. DPA can order complete cessation of processing.
📋 Audit Questions
- 1.Which processing activities have undergone DPIA?
- 2.How do you determine which activities require a DPIA?
- 3.Show a completed DPIA for your highest-risk processing activity.
- 4.How are DPIA findings tracked and remediated?
⚡ Common Pitfalls
- ⛔Not recognizing when processing is 'high risk' (profiling, large-scale monitoring, sensitive data)
- ⛔Conducting a DPIA as a one-time exercise instead of ongoing review
- ⛔DPIA completed but findings not addressed or remediated
📈 Business Value
DPIAs demonstrate proactive privacy governance and prevent enforcement actions before they occur. They're increasingly required for enterprise procurement and B2B sales in the EU.
⏱️ Effort Estimate
16-40 hours per DPIA for complex processing activities
EchelonGraph provides compliance scoring to help identify high-risk processing activities
🔗 Cross-Framework References
Automate GDPR Art35 compliance
EchelonGraph continuously monitors this control across all your cloud accounts.
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