The GDPR Privacy Assessment is a crucial document required for organizations operating under Irish and EU data protection law. It should be conducted when implementing new data processing activities, making significant changes to existing processes, or as part of regular compliance reviews. The assessment helps organizations demonstrate accountability under Article 5(2) of GDPR and may form part of mandatory Data Protection Impact Assessments (DPIAs) when required under Article 35. The document specifically addresses requirements of both the EU GDPR and the Irish Data Protection Act 2018, providing a structured evaluation of privacy risks and compliance measures. It includes detailed analysis of data processing activities, legal bases for processing, security measures, and recommendations for addressing identified risks.
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1. Executive Summary: High-level overview of the assessment findings, key risks identified, and major recommendations
2. Assessment Context: Purpose, scope, and background of the privacy assessment, including the processing activities being assessed
3. Organizational Overview: Description of relevant organizational structure, data protection roles, and responsibilities
4. Data Processing Inventory: Detailed analysis of personal data processing activities, including data types, purposes, and processing operations
5. Legal Basis Assessment: Evaluation of the legal grounds for processing under Article 6 and special category data under Article 9 of GDPR
6. Data Protection Principles Assessment: Analysis of compliance with GDPR principles under Article 5
7. Risk Assessment: Identification and evaluation of privacy risks to individuals' rights and freedoms
8. Technical and Organizational Measures: Assessment of existing security measures and controls
9. Data Subject Rights: Evaluation of processes for handling data subject rights requests
10. Recommendations: Detailed recommendations for addressing identified risks and compliance gaps
11. Implementation Plan: Proposed timeline and actions for implementing recommendations
1. International Data Transfers: Assessment of cross-border data transfers and appropriate safeguards - include when international data flows are present
2. Processor Assessment: Evaluation of data processors and their compliance - include when third-party processors are involved
3. Special Category Data Analysis: Detailed assessment of special category data processing - include when processing sensitive personal data
4. Children's Data Processing: Specific assessment of children's data processing activities - include when processing children's data
5. Privacy by Design Review: Assessment of privacy by design implementation in systems and processes - include for new projects or significant changes
6. Data Protection Impact Assessment: Full DPIA analysis - include when processing is likely to result in high risk to individuals
7. Legitimate Interests Assessment: Detailed LIA documentation - include when legitimate interests is used as legal basis
1. Appendix A - Data Flow Maps: Visual representations of data flows and processing activities
2. Appendix B - Risk Register: Detailed log of identified risks, their likelihood, impact, and mitigation measures
3. Appendix C - Processing Records: Detailed inventory of processing activities in Article 30 format
4. Appendix D - Security Controls Matrix: Detailed assessment of technical and organizational security measures
5. Appendix E - Compliance Checklist: Detailed checklist of GDPR compliance requirements and their status
6. Appendix F - Stakeholder Consultation Records: Documentation of consultations with relevant stakeholders
7. Appendix G - Action Plan: Detailed implementation plan with timelines and responsibilities
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