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Data Privacy Impact Assessment Template for United Arab Emirates

A Data Privacy Impact Assessment (DPIA) document customized for UAE compliance requirements, including Federal Decree-Law No. 45/2021 and relevant free zone regulations such as DIFC and ADGM data protection laws. This systematic assessment tool evaluates privacy risks associated with data processing activities, ensuring compliance with UAE's data protection framework. The document provides a structured approach to identifying, assessing, and mitigating privacy risks while demonstrating accountability to UAE regulatory authorities and maintaining documentation of privacy risk management decisions.

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What is a Data Privacy Impact Assessment?

The Data Privacy Impact Assessment (DPIA) is a mandatory requirement under UAE Federal Decree-Law No. 45/2021 for certain types of high-risk data processing activities. This document should be used when implementing new systems, processes, or technologies that involve processing personal data, particularly when the processing is likely to result in high risks to individuals' rights and freedoms. The DPIA helps organizations comply with UAE data protection requirements, including specific regulations in financial free zones like DIFC and ADGM. It provides a systematic approach to evaluating privacy risks, documenting compliance measures, and demonstrating accountability to regulatory authorities. The assessment must be conducted before processing begins and should be regularly reviewed throughout the project lifecycle.

What sections should be included in a Data Privacy Impact Assessment?

1. Executive Summary: Overview of the DPIA findings, key risks identified, and main recommendations

2. Project Overview: Description of the data processing activity, system, or project being assessed

3. Data Processing Information: Detailed description of personal data types, processing purposes, legal bases, and data flows

4. Necessity and Proportionality Assessment: Evaluation of whether the processing is necessary and proportionate to achieve the intended purposes

5. Compliance Assessment: Analysis of compliance with UAE data protection laws and regulations

6. Risk Assessment: Identification and evaluation of privacy risks to individuals' rights and freedoms

7. Risk Mitigation Measures: Proposed controls and measures to address identified risks

8. Residual Risks: Assessment of remaining risks after implementation of mitigation measures

9. DPO/Privacy Expert Recommendations: Professional opinion on the processing activity and additional measures required

10. Sign-off and Approval: Formal approval section for relevant stakeholders and decision-makers

What sections are optional to include in a Data Privacy Impact Assessment?

1. Cross-Border Transfer Assessment: Required when personal data will be transferred outside the UAE, analyzing compliance with transfer requirements

2. Special Categories Data Assessment: Required when processing sensitive personal data, including additional safeguards

3. Technical Security Assessment: Detailed evaluation of technical security measures when processing involves complex technology

4. Vendor/Processor Assessment: Required when third-party processors are involved in data processing activities

5. Data Subject Consultation: Summary of any consultation with affected individuals or their representatives

6. Free Zone Specific Compliance: Required when processing occurs within DIFC or ADGM, addressing specific free zone requirements

What schedules should be included in a Data Privacy Impact Assessment?

1. Data Flow Diagrams: Visual representations of how personal data flows through the system/process

2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrix

3. Processing Records: Detailed inventory of processing activities covered by the DPIA

4. Technical and Organizational Measures: Detailed documentation of security and privacy measures

5. Stakeholder Consultation Records: Documentation of consultations with relevant parties

6. Compliance Checklist: Detailed checklist against relevant UAE data protection requirements

7. Action Plan: Detailed implementation plan for recommended measures

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents

Publisher

Genie AI

Cost

Free to use

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