Data protection impact assessment (DPIA)

We conduct mandatory DPIAs to identify and mitigate privacy risks in high-risk data processing activities under DIFC DPL, ADGM DPR, UAE PDPL, and other regulations. Our assessments help you catch compliance failures before they happen.

Key Benefits:

✔ Meet regulatory requirements for high-risk processing

✔ Identify and reduce data protection risks

✔ Document compliance for regulators

✔ Avoid costly penalties and reputational damage

What is a data protection impact assessment?

A DPIA is a structured assessment, carried out before you start a project, that identifies privacy risks to individuals and records how you will reduce them. It shows regulators, customers and partners that you considered the impact on people up front rather than after something went wrong.

When is a DPIA required?

• GDPR and UK GDPR (Article 35): required where processing is likely to result in a high risk to individuals, in particular systematic and extensive profiling with significant effects, large-scale processing of sensitive data, and systematic monitoring of public areas.
• UAE PDPL (Article 21): requires an assessment before processing that is likely to pose a high risk, and explicitly names processing that uses new technologies and systematic evaluation of personal aspects through automated means.
• DIFC DPL and ADGM DPR: both require assessments for high-risk processing, with their own triggers and guidance.
• Saudi PDPL: its Implementing Regulations also call for risk and impact assessments for certain types of processing.

Common triggers include launching AI or machine-learning features, rolling out employee monitoring, building a customer-profiling or scoring model, processing health or biometric data, and large new data-sharing arrangements. Even where a DPIA is not strictly required, it is good practice for any project with meaningful privacy risk. This page is general information, not legal advice.

What a DPIA contains

• A description of the processing: what data, whose data, why, how and for how long
• An assessment of necessity and proportionality, including the legal basis and data minimisation
• An assessment of the risks to individuals, such as discrimination, loss of control, security exposure or unexpected use
• The measures that will address those risks, with an owner and a date for each
• Consultation with relevant stakeholders and, where required, with the regulator
• Sign-off and a plan for reviewing the assessment as the project changes

How we run a DPIA

1. Screening: we confirm whether a full DPIA is needed and agree its scope.
2. Information gathering: workshops with your product, IT, legal and business teams, plus review of data flows, vendors and documentation.
3. Risk analysis: we identify and rate the risks to individuals and test the project against each applicable law.
4. Mitigation plan: practical, prioritised recommendations your team can act on.
5. Report and sign-off: a clear written DPIA you can show to a regulator, auditor or customer.
6. Review: a trigger list and schedule for revisiting the DPIA when the project changes.

DPIA, transfer impact assessment and gap analysis: what is the difference?

A DPIA looks at the risks of a specific project to the people whose data is involved. A transfer impact assessment looks at the risks of sending personal data to another country. A gap analysis compares your overall privacy programme against legal requirements. Many projects need more than one, and we can combine them.

Frequently asked questions

Who is responsible for the DPIA?

The organisation deciding why and how the data is used, known as the controller, is responsible. The Data Protection Officer advises on it but does not carry the responsibility. We can support or lead the assessment, and our DPO-as-a-Service includes advice on DPIAs.

When should we do a DPIA?

Before the processing starts, ideally at the design stage when changes are still cheap. A DPIA done after launch is far less useful.

Do AI projects need a DPIA?

Often, yes, particularly where AI involves profiling, automated decisions with significant effects or sensitive data. See our AI governance service and the AI governance checklist.

What if the DPIA shows a high residual risk?

You should either change the project to reduce the risk or, where the law requires, consult the regulator before proceeding. We help you decide which route fits.

How long does a DPIA take?

It depends on the complexity of the project and how quickly information is available. We agree a realistic timeline when we scope the work.