To start, it's essential to clarify the terms themselves. PIA and DPIA are both tools employed to evaluate and manage potential risks associated with data processing activities. However, their focus areas and the stages at which they come into play differ.
In essence, the PIA serves as a preliminary screening, while the DPIA is a more thorough risk assessment that becomes necessary if significant risks are identified during the initial PIA.
PIA: Safeguarding privacy from the start
- Conducted at the early stages of a project or system development.
- Focuses on identifying and mitigating potential privacy risks associated with data processing.
- Not mandatory to make, but it is a proactive approach to ensuring compliance.
Consider a scenario where a company plans to launch a new customer relationship management (CRM) system. Before the system goes live, a PIA is conducted to assess the impact on individuals' privacy. This involves evaluating the type of data collected, the purpose of the data processing, and implementing measures to protect individual privacy rights.
ICO has created some simple screening questions to help organisations identify when a PIA is needed.
DPIA: Mitigating risks in high-stakes data processing
- Conducted when data processing activities pose a high risk to individuals' rights and freedoms.
- Mandatory and more comprehensive in-depth assessment, evaluating specific risks associated with high-risk data processing.
- Involves not only project stakeholders but also the Data Protection Officer (DPO) and data subjects.
Let's consider a real-life example to illustrate the need for a DPIA. Suppose a healthcare organisation plans to implement a new system for processing genetic data, involving sensitive information about patients' health. Due to the nature of this processing activity and the potential impact on individuals, a DPIA is crucial to identify, assess and mitigate risks.
Combine the ideas
Getting started early is crucial for privacy professionals. Therefore, we suggest that organisations combine the different ideas behind the PIA and the DPIA.
By utilising the comprehensive framework of the DPIA, and the speediness of the PIA, organisations can provide advice on new systems while simultaneously conducting an in-depth analysis when necessary.
In conclusion, while both PIA and DPIA aim to protect personal data, they operate at different stages of a project and cater to distinct levels of risk. It might even be rare that a full DPIA is needed. Effectively implementing these assessments is not just a legal requirement; it's a commitment to securing a safer, more privacy-conscious future for people in our digitised society.
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