Prompt:
Privacy Impact Assessments (PIAs) and Data Protection Impact Assessments (DPIAs) are all about assessing “risk to the rights and freedoms” of individuals — but what exactly does that risk look like? When is a risk real enough to act on, and when is it acceptable or negligible?
Answer the following:
- In a DPIA, how would you decide whether a processing activity presents a “high risk”? What criteria would you use?
- Can an organization complete a DPIA and still go ahead with high-risk processing? If yes, how? If no, why not?
- Compare the thresholds and triggers for mandatory DPIAs in laws like GDPR, DPDPA, and others. Do they match or conflict?
- Explain the role of risk scoring, likelihood vs impact, and how you would justify a decision in case of regulator scrutiny.
Scenario-Based Bonus (Play Consultant):
You’re hired by a mental health app startup. They collect mood data, journaling entries, user behavior patterns, and location to improve UX. They pseudonymize user IDs but keep IP addresses for analytics.
They say DPIA is “not mandatory” because they don’t identify users.
You disagree.
Write your argument. Should they conduct a DPIA? Why or why not? Use legal, ethical, and business risk reasoning.
Instructions for Learners:
- Show your risk judgment – this is the real skill companies hire for.
- Use DPIA tools, checklists, or logic trees if helpful.
- Be concise but sharp. ~300–500 words recommended.
- Think: What would your defensible logic be in front of a regulator, auditor, or CISO?
Background Concepts to Explore
- Article 35 GDPR – DPIA triggers
- ICO’s High-Risk Processing Checklist
- India DPDPA’s approach to significant harm
- EDPS Risk Matrix
- Ethical risk vs legal risk
