The Data Protection Impact Assessment Policy is designed to ensure organizations comply with Article 35 of the GDPR and Irish data protection requirements when processing personal data that may result in high risks to individuals' rights and freedoms. This document becomes necessary when organizations engage in systematic monitoring, large-scale processing of sensitive data, or innovative use of new technologies. The policy provides comprehensive guidance on conducting DPIAs, including risk assessment methodologies, stakeholder consultation requirements, and documentation procedures. It is particularly relevant for organizations operating in Ireland, considering both the requirements of the Irish Data Protection Commission and the broader EU regulatory framework. The policy must be regularly reviewed and updated to reflect changes in data protection law, regulatory guidance, and emerging best practices.
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1. Purpose and Scope: Defines the purpose of the policy and its scope of application within the organization
2. Definitions: Key terms used throughout the policy, including technical and legal terminology
3. Legal Framework and Compliance Requirements: Overview of relevant legislation and regulatory requirements
4. Roles and Responsibilities: Defines who is responsible for conducting, reviewing, and approving DPIAs
5. DPIA Triggers and Threshold Assessment: Criteria for determining when a DPIA is required
6. DPIA Process and Methodology: Step-by-step guidance on how to conduct a DPIA
7. Risk Assessment Framework: Methodology for assessing and scoring privacy risks
8. Consultation Requirements: Guidelines for internal and external stakeholder consultation
9. Documentation and Record Keeping: Requirements for maintaining DPIA records and evidence
10. Review and Monitoring: Procedures for ongoing monitoring and periodic review of completed DPIAs
11. Non-Compliance and Enforcement: Consequences of non-compliance and enforcement measures
1. International Data Transfers: Additional requirements for DPIAs involving international data transfers, particularly relevant for multinational organizations
2. Sector-Specific Requirements: Additional requirements for specific sectors such as healthcare, financial services, or public sector
3. Technology-Specific Considerations: Specific guidance for new or high-risk technologies such as AI, biometrics, or IoT
4. Emergency DPIA Procedures: Expedited DPIA procedures for emergency situations or time-critical processing
5. Data Protection Officer Integration: Specific procedures for organizations with a designated DPO
6. Vendor and Third-Party Assessments: Additional guidance for assessing data processors and third-party risks
1. DPIA Screening Questionnaire: Template questionnaire to determine if a DPIA is required
2. DPIA Template: Standard template for conducting DPIAs
3. Risk Assessment Matrix: Template for scoring and evaluating privacy risks
4. Stakeholder Consultation Template: Template for documenting stakeholder consultations
5. DPIA Review Checklist: Checklist for reviewing completed DPIAs
6. Data Flow Mapping Template: Template for mapping data flows as part of the DPIA process
7. Sample Mitigation Measures: List of common risk mitigation measures and controls
8. DPIA Register Template: Template for maintaining a register of all DPIAs
9. Prior Consultation Form: Template for DPC consultation when required
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