DPIA Template: Follow These Steps for Your Data Protection Impact Assessments

The General Data Protection Regulation (GDPR) contains plenty of requirements, penalties, obligations, rights, and definitions—but it doesn’t contain a specific template for DPIAs, or data protection impact assessments.

If you’re struggling to identify exactly what your DPIA is supposed to contain, you can review this blog to find out how to start. We’ll walk through what a DPIA is, the actual template itself, and then provide guidance on how you can make the DPIA process and workflow faster and easier.

Data Protection Impact Assessments: The Basics as Per the GDPR

DPIAs are covered in Article 35 of the GDPR, and here's what it has to say:

Where a type of processing [...] is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall, prior to the processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data.

It goes on to list three specific circumstances where a DPIA is required, though this list is not exhaustive:

• Data processing activities that involve automated decision-making.
• Processing special categories of data (such as data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and others).
• Systematic monitoring of a public area.

Generally speaking, any major project that involves personal data should have a DPIA associated with it.

For more details, take a look at What Is a DPIA (Data Protection Impact Assessment)?

DPIA Requirements Outside the EU

While the GDPR formally requires organizations to carry out a DPIA in certain cases, other global privacy laws also include privacy impact assessments or similar obligations for high-risk processing of personal data.

United States

Under Virginia’s VCDPA, businesses must conduct data protection assessments when activities involve sensitive data, profiling, or targeted advertising. These assessments serve to demonstrate compliance and are comparable to GDPR requirements.

California’s CCPA, as amended by the CPRA, requires businesses to conduct risk assessments for certain types of data processing that could pose significant privacy or security risks to consumers. However, specific rules on when businesses must carry them out are still being finalized. Organizations should prepare based on CPPA’s forthcoming guidelines on DPIAs.

Brazil

Brazil’s LGPD doesn’t mandate a DPIA in all cases but authorizes the national regulator to request one, especially when processing is based on legitimate interest or involves data concerning health, biometrics, or other sensitive categories. In these cases, businesses may also want to prepare assessments to demonstrate compliance proactively.

Canada

Under PIPEDA, privacy impact assessments (PIAs) are considered a best practice, especially for cross-border transfers or when using a data processor. These assessments help evaluate data security risks and support efforts to comply with the GDPR where applicable.

Australia

Australia’s Privacy Act requires public agencies to complete a PIA for high-risk projects. While not mandatory for private companies, PIAs are encouraged when processing personal data in ways that could raise data protection issues.

In short, while only some laws formally require a DPIA, many encourage similar assessments to reduce risk and ensure responsible use of personal data. A unified approach can help your global organization meet multiple regulatory expectations and demonstrate compliance.

Sample DPIA Template

1. Identify whether a DPIA is required

Provide a summary of why you believe the project needs a DPIA. What does it aim to achieve, and what type of processing does it involve? Refer to supporting documents, such as project proposals, as needed.

2. Describe the processing

You’ll want to detail the nature, scope, context, and purpose of the processing. That includes answering questions like:

• Nature of the processing: How do you intend to use the data? Will you share it with others? Are there high-risk processing activities involved?
• Scope of the processing: Does the data include special category data or data related to criminal offences? How much data will you collect and process? When will you delete the data? How many individuals will be affected by the processing, and how many geographical regions will be involved?
• Context of the processing: What is your relationship with the data subjects? Do they know about how you intend to use their data, and do they have control over that process? Are there any public concerns associated with the intended use of the data? Are other frameworks, codes of conduct, or certification schemes involved?
• Purpose of the processing: What are your intended goals? What are the benefits of the processing for both your organization and the broader world?

3. Consult With Experts and Record Their Responses

What other experts and stakeholders will you include in your DPIA, and what was their feedback? Did you speak with the individuals likely to be impacted by the processing, information security and privacy experts, or downstream processors?

4. Assess necessity and proportionality

This step in your DPIA is all about determining whether the processing really needs to or should occur in the first place. Do you have a solid lawful basis for the processing? Does the processing actually achieve your goal, and are you only collecting the data that you absolutely need to do so? Are there alternative approaches that don’t require data collection? Ask yourselves questions along these lines and record the relevant information here.

5. Identify and Assess Risks

Make sure to identify and list the sources and nature of various risks that could be associated with the processing. For each of these risks, score their:

• Likelihood of harm—is it remote, possible, or probable?
• Severity of Harm—is it minimal, significant or severe?
• Overall risk—is it low, medium, or high?

6. Identify Measures to Reduce Risk

Based on the risks you previously identified, list out the measures you could take to reduce or eliminate them, focusing especially on the high and medium risks.

Then, describe the impact you’ve had on the identified risk, including:

• Whether the risk has been eliminated, reduced, or is merely being accepted.
• Whether there is low, medium, or high residual risk.
• Whether the intervention has been approved as being sufficient.

7. Sign Off and Record Outcomes

Create a record of approvals and outcomes. This should include:

• Who approved various measures, their integration into the project plan, as well as the date and responsibility for completion.
• Who approved the residual risks. If any residual risk is found to be high risk, then your local data protection authority should be consulted first. Their approval or disapproval ought to be recorded here.
• What advice your DPO provided, such as compliance, risk reduction measures from step 6, and whether the processing can proceed.
• Whether the DPO’s advice was accepted or overruled, by whom, and for what reasons.
• Who reviewed the responses of consulted experts, whether decisions departed from these individuals’ view, and why.
• How the DPO assesses ongoing project compliance with the DPIA over time.

Best Practices for Carrying Out a DPIA

Conducting a DPIA is more than a regulatory checkbox—it’s a proactive way to identify and address potential data protection issues before they become liabilities. Whether you're new to DPIAs or looking to refine your approach, these best practices can help you demonstrate compliance and minimize risk.

1. Start early and plan ahead

Organizations that process personal data should aim to carry out a DPIA as early as possible in the project lifecycle—ideally during the design or procurement phase. This ensures that data protection considerations are built in from the beginning.

2. Involve the right people

A DPIA is a collaborative effort. You must consult with internal stakeholders like product teams, security, legal, and especially your Data Protection Officer (DPO) if your organization is required to appoint one. If your project involves the use of a data processor, their input is also essential.

3. Focus on individuals, not just the business

The goal of a DPIA is to assess how the processing of personal data may impact individuals’ rights and freedoms. Consider how the use of personal data could result in harm, such as discrimination, identity theft, or loss of control over personal information.

4. Follow regulator-endorsed frameworks

To ensure your assessment meets the criteria for an acceptable DPIA, refer to regulator-issued guidance such as the European Data Protection Board’s guidelines on DPIAs or the UK ICO’s templates. These provide helpful tools to help assess risk, weigh mitigations, and determine when you need to consult supervisory authorities.

5. Document and update your DPIA

A DPIA should include a clear assessment of the necessity and proportionality of the processing of personal data, a description of safeguards, and a summary of stakeholder input. It’s also important to revisit your DPIA when significant changes occur—such as onboarding a new data processor or launching a new product feature.

The Core Challenge of Conducting a DPIA

Filling out a form according to these instructions is straightforward enough—but the reality of implementing them on a per-project basis is complex.

DPIAs need to be conducted before work can begin, and they must be maintained as work goes on. That means multiple stakeholders need to be aligned in terms of what their contributions must be and when they must be made. Consider the different parties involved:

• Your organization’s DPO.
• Project leads.
• The data subjects and other impacted individuals.
• Security, privacy, and other subject matter experts.
• Downstream processors, such as your vendors.
• Your local data protection authorities.

Some of these stakeholders can’t be rushed (like your local data protection authority), which means receiving timely information from the parties you have a working relationship with (such as your colleagues, DPO, and vendors) is essential.

Moreover, assessments like these need to be conducted and maintained on a regular basis. As they build up, it can be easy for a DPO or other privacy professional to lose track of which DPIAs are out of date, which are awaiting input from DPIA stakeholders, and so on.

That’s why DPOs and privacy professionals should look for a data privacy management platform with a built-in assessments module. In the Osano platform, you can:

• Assign stakeholders action items.
• Send automated reminders.
• Schedule regular review cadences.
• Review the status of current assessments.
• Store and centralize assessments.

That’s not to mention the library of other assessment types and custom assessment functionality in Osano—or its suite of additional privacy solutions.

Schedule a demo of the Osano Platform today! Or, if you’d like to walk through the DPIA process on your own to understand requirements, download a DPIA template here.

Get a demo of Osano today

DPIA Template

Want quick access to an editable version of this template so you can comply with the GDPR and other privacy regulations? Download our DPIA template here.