DPIA v. PIA: What’s the difference?

Introduction  

With the advent of multiple #privacy legislations around the globe, it becomes essential for business organizations to start investing and implementing privacy programs inside their organization. The two essential concepts in data privacy & protection are- Data Protection Impact Assessment (DPIA) and Privacy Impact Assessment (PIA). Business organizations often time use DPIA & PIA interchangeably, as both terms sound quite similar to one another. However, both these terms serve a separate purpose altogether. The two terms neither are synonyms to each other nor are to be used interchangeably. 

DPIA & PIA  

A DPIA or Data Protection Impact Assessment is a process of documentation with an aim to identify and mitigate potential threats/risks associated with the processing of users’ personal data by an organization. An organization must carry out DPIA especially during the processing of sensitive personal data; while carrying out large-scale processing of users’ personal data, and during automated decision-making. A DPIA is a mandatory compliance requirement under the General Data Protection Regulation (GDPR). 

On the other hand, a PIA or Privacy Impact Assessment is a process to ensure and enable privacy by design in an organization. PIAs are carried out by the privacy teams of an organization especially for assessing organizational privacy risk when a new business process is implemented; during business acquisition, and/or product is launched. With this said, PIAs are not just limited when something new is being implemented, rather they will still be carried out to the existing processes when they’re altered (eg. When the business organization is expanding its business to a different jurisdiction). 

Whereas, DPIAs are many times used as evidence in order to showcase that the organization has already assessed the potential threats associated with processing activities and further has eliminated such threats. Such documentary evidence can be shared with the concerned Data Protection Authority/Board, if and when required. 

Final thoughts 

Business organizations are not mandated to publish the outcomes of their DPIAs. However, they are still required to maintain a complete detailed record of all the potential threats which were identified during the DPIA, and how they were treated. 

Both DPIA & PIA serves a vital role in implementing data privacy & protection inside an organization. PIAs essentially focus on assessing how changes, alterations, modifications, etc impact a business organization’s privacy & security systems and what all potential risks may further impact such an organization, and whether such an organization has controls in place or not. 

Lastly, DPIAs are essential because it is carried out to assess whether the #dataprocessing could put the data subjects at high risk, compromising their privacy rights.