The Data Privacy Impact Assessment (DPIA) is a mandatory requirement under Swiss data protection law for processing activities that may result in high risks to the rights and freedoms of natural persons. This document becomes necessary when implementing new technologies, processing sensitive data on a large scale, or conducting systematic monitoring of public areas. It must align with the requirements of the Federal Act on Data Protection (FADP/LPD) and its ordinance, while also considering EU GDPR standards due to Switzerland's position as a third country seeking adequacy status. The DPIA helps organizations demonstrate accountability, identify privacy risks early in project development, and implement appropriate safeguards. It serves as both a compliance tool and a practical guide for privacy-by-design implementation.
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1. Executive Summary: High-level 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 categories, processing purposes, and data flows
4. Necessity and Proportionality Assessment: Evaluation of whether the processing is necessary and proportionate to its purposes, considering Swiss legal requirements
5. Risk Assessment: Identification and analysis of privacy risks to individuals' rights and freedoms
6. Risk Mitigation Measures: Detailed description of existing and proposed measures to address identified risks
7. Legal Compliance Analysis: Assessment of compliance with FADP and other relevant Swiss legal requirements
8. Consultation Process: Details of consultations with stakeholders, including the DPO if applicable
9. Recommendations: Specific actions required to ensure compliance and risk mitigation
10. Conclusion: Final determination on whether processing can proceed and under what conditions
1. Cross-border Data Transfers: Assessment of international data transfers and associated safeguards, required when data is transferred outside Switzerland
2. Sector-Specific Compliance: Additional assessment for regulated sectors (e.g., financial services, healthcare), needed when operating in these industries
3. Technical Security Assessment: Detailed evaluation of technical security measures, recommended for complex IT systems
4. Data Processor Assessment: Evaluation of third-party service providers and their compliance, needed when external processors are involved
5. Special Categories of Data: Additional assessment for sensitive data categories, required when processing sensitive personal data
6. Automated Decision-Making: Assessment of automated processing impacts, required when automated decision-making is used
7. Children's Data Processing: Special considerations for processing children's data, required when processing minors' personal data
1. Appendix A - Data Flow Diagrams: Visual representations of data flows, systems, and processing activities
2. Appendix B - Risk Assessment Matrix: Detailed risk scoring and evaluation matrices
3. Appendix C - Technical and Organizational Measures: Detailed documentation of security measures and controls
4. Appendix D - Stakeholder Consultation Records: Documentation of consultations with relevant parties
5. Appendix E - Processing Records Inventory: Detailed inventory of processing activities and data categories
6. Appendix F - Compliance Checklist: Detailed checklist against FADP requirements and other applicable laws
7. Appendix G - Action Plan: Detailed implementation plan for recommended measures
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