Assess a high-risk processing activity before it ships, documenting risks, mitigations, and the decision. Use when processing sensitive data, profiling at scale, or introducing a novel use of personal data.
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---
name: privacy-impact-assessment
description: Assess a high-risk processing activity before it ships, documenting risks, mitigations, and the decision. Use when processing sensitive data, profiling at scale, or introducing a novel use of personal data.
---
# Privacy impact assessment
An assessment is a structured argument that a processing activity is
justified and its risks are controlled. Its value is catching the
unacceptable design before it is built, and leaving a record of why the
acceptable one was accepted.
## Method
1. **Describe the processing plainly.** What data, whose, for what
purpose, by what means, retained how long, shared with whom. Most
problems surface while writing this section honestly.
2. **Test necessity and proportionality.** Could the purpose be met
with less data, weaker identifiers, or shorter retention? If yes,
the design changes rather than the assessment concluding it is fine
(see data-minimization).
3. **Identify risks from the person's side.** Not risk to the company
but harm to the individual: exposure, discrimination, unexpected
inference, loss of control. This reframing is what makes the
exercise useful rather than procedural.
4. **Attach a mitigation to each risk, with an owner.** Access control,
anonymisation, retention limits, transparency, and opt-outs, each
assigned rather than listed (see privacy-by-design).
5. **State the residual risk and who accepted it.** Some risk always
remains, and naming the accountable person is the difference between
a decision and a document.
6. **Revisit when the processing changes.** New data sources, new
purposes, or new scale invalidate the original conclusion, so tie
review to those triggers.
## Boundaries
- Whether an assessment is legally required, and what it must contain,
varies by jurisdiction and is a legal determination.
- An assessment documents and reduces risk; it does not authorise
processing that lacks a lawful basis.
- It is a design-time tool, so running it after launch salvages
documentation but not the design choices already made.