www.azpirantz.com | 02 Table of Contents 1. Introduction..........................................................................................................................03 2. What Are PIA and DPIA?..................................................................................................04 3. Why Integrate Assessments into Every Project?.................................................05 4. Embedding PIA/DPIA into the Project Lifecycle................................................07 5. Best Practices for Effective PIA/DPIA Programs................................................. 10 6. How Azpirantz Can Help?................................................................................................12 7. Conclusion..............................................................................................................................14 www.azpirantz.com | 03 Introduction When every project touches personal data, safeguarding privacy is not just good practice; it is mission-critical for earning trust and staying on course. Organizations collect and use personal data at unprecedented scale, and each new product or initiative can introduce potential privacy pitfalls. Regulators worldwide are sharpening their teeth: for example, the EU’s GDPR mandates Data Protection Impact Assessments (DPIAs) for high-risk processing, with fines up to 4% of annual turnover for non-compliance. Similarly, new U.S. state laws (California, Colorado, Virginia, Connecticut) now require Privacy Impact Assessments (PIAs) for certain sensitive data uses. Beyond legal mandates, proactive privacy assessments build trust and prevent “the spark that burns your business down” by catching issues before they explode into breaches or scandals. This whitepaper explores how to operationalize PIAs and DPIAs across all projects, embedding them into your organization’s DNA; and how Azpirantz’s expertise can help make privacy by design a living reality. www.azpirantz.com | 04 What Are PIA and DPIA? Privacy Impact Assessment (PIA): A PIA is an internal risk evaluation for the organization. It examines how a product, service, system, or process handles personal data and asks “Could this hurt us?” in terms of business risk. In practice, a PIA identifies and documents data flows and behaviors across systems containing personal information, then gauges how those practices align with privacy requirements and corporate risk appetite. It’s like an early-warning system; an “internal smoke detector” that rings alarm bells about privacy concerns before regulators or customers do. Organizations typically conduct PIAs at the start of new projects or major changes (new product launches, new data collection practices, mergers, etc.) and even for significant changes to existing processes. Data Protection Impact Assessment (DPIA): A DPIA is a more specific type of impact assessment focused on risks to individuals. It asks “Could this hurt them?”: “them” meaning the data subjects whose information is processed. DPIAs are required under laws like GDPR Article 35 whenever data processing is likely to result in high risk to individuals’ rights and freedoms. The DPIA process entails a systematic description of the intended processing, an assessment of its necessity and legal basis, an evaluation of the potential impacts on people’s privacy, and a plan to address those impacts. Essentially, PIA and DPIA share the same core concept; assessing privacy risks and controls, but DPIAs apply to higher-risk scenarios and have more clearly defined content requirements under regulations. www.azpirantz.com | 05 Why Integrate Assessments into Every Project? Making PIAs and DPIAs a standard part of project planning is not just about compliance, it is about smart business and ethical data use. Regulatory Compliance and Avoiding Penalties: The most obvious driver is obeying the law. GDPR’s DPIA mandate and the expanding patchwork of privacy laws mean failing to do an assessment when required can lead to hefty fines or enforcement actions. For example, California’s CPRA will even require businesses to file certain PIAs with regulators or be prepared to produce them on request. Early Risk Identification: By performing PIAs, companies can spot and address privacy risks early, “ringing alarm bells before regulators (or customers) do”. Identifying issues (say, unnecessary data collection or inadequate security) in the design phase means they can be fixed or mitigated before they become problems. Privacy by Design and Trust: Operationalized PIAs/DPIAs bake privacy by design into your development culture. The assessments force project teams to think about data minimization, transparency, and user rights from day one. This not only reduces the chances of harm to individuals but also builds customer trust. Consumers and clients increasingly choose businesses that demonstrate care for personal data. Organizational Insight and Strategy: The process of doing PIAs and DPIAs yields valuable knowledge about your data practices enterprise-wide. It is a chance to map data flows, discover shadow data processes, and break down silos between departments. Preventing Reputational and Business Harm: Beyond legal fines, a privacy incident can erode customer confidence and brand value. A well-executed DPIA asks you to step into the individual’s shoes, “now I’m the data subject”, and consider how your project could negatively affect them. www.azpirantz.com | 06 www.azpirantz.com | 07 Embedding PIA/DPIA into the Project Lifecycle Operationalizing PIAs and DPIAs means making them a standard practice for every relevant project, rather than an ad-hoc or “checkbox” exercise. Here’s how organizations can integrate these assessments into their workflows: Trigger at Project Inception: Treat a PIA as a mandatory project kickoff activity when personal data is involved. As soon as a new product, feature, or process is being designed, privacy team members should engage with project owners to do a preliminary assessment. Map Data Flows and Identify Data: An effective assessment depends on knowing what data will be collected, used, or changed by the project. Thus, teams should document data flows and inventory personal information at the outset. This involved updating your Record of Processing Activities (RoPA) or doing a quick data mapping exercise for the project. Understanding the nature of the data (Is it sensitive? Does it include children’s data? etc.) and the context of processing (third-party involvement, cross-border transfers, etc.) is crucial to scope the PIA/DPIA appropriately. Assess Risks to Individuals and the Organization: With the data mapping in hand, the PIA/DPIA process can analyze potential risks. This usually involves cross-functional brainstorming to identify how the planned processing could impact individuals’ privacy rights (e.g., could it lead to profiling, www.azpirantz.com | 08 bias, security breaches exposing sensitive info?) as well as how it could impact the organization (e.g., non-compliance penalties, reputation damage). Determine PIA vs. DPIA Requirements: At this stage, confirm whether a DPIA is legally required (or just prudent to do). If the project meets one or more high-risk criteria defined by law, for example, processing sensitive personal information on a large scale or using AI for decisions, a formal DPIA is mandatory. Mitigation Planning: A core purpose of these assessments is not just to list risks, but to figure out how to address them. For each identified risk or potential negative impact, the team should design mitigation measures. These could include technical controls (encryption, access restrictions, data minimization techniques), policy changes, enhanced user transparency/consent flows, training for staff, or even cancelling or redesigning aspects of the project if the risk is unjustifiable. The assessment report should clearly record how you plan to reduce or eliminate each risk. Documentation and PIA/DPIA Report: As part of operationalizing, establish a standardized template or framework for the PIA/DPIA report so that every project’s assessment covers the necessary components. According to industry best practice and legal guidance, an assessment report should include at least: (1) a description of the project (and its purpose), (2) the scope and context of data processing, (3) the identified privacy risks (both to individuals and the organization), and (4) the measures and controls to mitigate those risks and demonstrate compliance. www.azpirantz.com | 09 Review and Approval Workflow: Embedding PIAs/DPIAs into project life means also setting up a clear review process. Assign a responsible privacy officer or committee to review each completed PIA/DPIA before the project proceeds. This review checks that risks have been properly identified and that the mitigation plan is adequate. It’s a safeguard to avoid “going through the motions” without real scrutiny. Only once the privacy team (and other stakeholders like InfoSec or Legal, as appropriate) sign off, should the project move to deployment. This ensures accountability. Communication and Action Tracking: Finally, operationalizing means treating the PIA/DPIA as actionable. The insights from the assessment should loop back into the project execution. For example, if the PIA flagged that the privacy notice needs updating to cover a new data use, ensure that task is assigned and completed before launch. www.azpirantz.com | 10 Best Practices for Effective PIA/DPIA Programs Making privacy impact assessments part of everyday operations requires not just doing them, but doing them well. Comprehensive and Consistent Approach: Develop a thorough methodology that covers the what, why, how, where, and who of data processing in each assessment. A checklist or framework can help assessors systematically consider all dimensions of privacy risk. Equally important is consistency, use the same rigorous process for every project, whether it is a minor app update or a major new system. Clarity and Plain Language: Ensure PIA/DPIA findings and reports are written in clear, non-technical language that stakeholders across the organization can understand. Avoid legalistic or overly technical jargon. The aim is to explain privacy risks and solutions as if you are “explaining privacy to your teenager”; i.e., no smoke and mirrors. Embed into Culture and Training: For PIAs and DPIAs to truly take root, the organization’s culture must encourage privacy-minded thinking. Train project managers and engineers on the basics of privacy impact assessments so they know when to flag projects for review and are prepared to collaborate. Consider establishing a privacy champions network in different departments to promote awareness. www.azpirantz.com | 11 Use Tools and Automation Where Possible: As privacy programs mature, leveraging technology can greatly assist in managing assessments. For example, some organizations use automated questionnaires and workflows to streamline data collection for PIAs, integrate with data inventories, and even automatically calculate risk scores based on inputs. Risk Strategy, Not a Checkbox”: Perhaps the most important best practice is a mindset shift. Don’t treat PIAs/DPIAs as a paperwork formality. Treat them as a core risk management practice. As one privacy expert noted, if your DPIA is “just a form, you’re already behind”. Instead, make it a genuine risk strategy exercise: use the assessment to deeply consider how to make the project not only compliant but genuinely safer for individuals. Continuous Monitoring and Updates: An operational PIA/DPIA program is not “one-and-done.” Build processes to revisit and update assessments when things change. If a project evolves to collect new data, or a new law comes into effect, or a previously identified risk worsens (maybe due to an external event or vulnerability), loop back and adjust the PIA/DPIA. Use Tools and Automation Where Possible: As privacy programs mature, leveraging technology can greatly assist in managing assessments. For example, some organizations use automated questionnaires and workflows to streamline data collection for PIAs, integrate with data inventories, and even automatically calculate risk scores based on inputs. Risk Strategy, Not a Checkbox”: Perhaps the most important best practice is a mindset shift. Don’t treat PIAs/DPIAs as a paperwork formality. Treat them as a core risk management practice. As one privacy expert noted, if your DPIA is “just a form, you’re already behind”. Instead, make it a genuine risk strategy exercise: use the assessment to deeply consider how to make the project not only compliant but genuinely safer for individuals. Continuous Monitoring and Updates: An operational PIA/DPIA program is not “one-and-done.” Build processes to revisit and update assessments when things change. If a project evolves to collect new data, or a new law comes into effect, or a previously identified risk worsens (maybe due to an external event or vulnerability), loop back and adjust the PIA/DPIA. www.azpirantz.com | 12 How Azpirantz Can Help? Operationalizing PIAs and DPIAs across all projects can be challenging; it requires the right mix of expertise, process design, and sometimes technology enablement. This is where Azpirantz comes in as a valuable partner. Azpirantz provides next-generation cybersecurity and data privacy consulting services to help organizations build privacy and cyber resilience from the inside out. When it comes to PIAs/DPIAs, Azpirantz offers comprehensive support to establish or improve your program: Framework Development: Azpirantz’s privacy experts work with your team to develop a customized PIA/DPIA framework that fits your industry, regulatory environment, and organizational structure. This includes creating templates, checklists, and standard operating procedures aligned with global best practices (e.g., GDPR standards, IAPP guidance) so that every assessment is thorough and compliant. Integration into Workflows: A big part of operationalizing is integrating assessments into existing project and risk management workflows. Azpirantz helps embed privacy checkpoints into your SDLC (Software Development Life Cycle) or project management stage gates. www.azpirantz.com | 13 Expert Consulting on High-Risk Assessments: For especially complex or high-risk projects (say, deploying a new AI system that uses sensitive data), Azpirantz can provide hands-on consulting to perform the DPIA in collaboration with your team. Our consultants stay up-to-date with the latest regulatory expectations and industry standards, so they can identify nuanced risks (like algorithmic bias or novel security concerns) and propose effective mitigations. Ongoing Support and Improvement: Operationalizing is an ongoing journey. Azpirantz does not just set you up and leave, we offer ongoing support to review and refine your PIA/DPIA program. This can include periodic audits of completed PIAs to ensure quality, updates to your framework when laws change (for example, incorporating new requirements from emerging privacy laws or standards), and scaling the program as your organization grows. By partnering with Azpirantz, organizations gain a holistic approach to privacy impact assessments, one that combines process rigor, technical savvy, and legal insight. The result is a PIA/DPIA program that not only keeps you compliant but actually powers your business forward by enabling safe, trusted, and innovative use of data. www.azpirantz.com | 14 Conclusion Privacy assessments are no longer optional, they are a cornerstone of responsible innovation. When embedded into every project, PIAs and DPIAs turn uncertainty into clarity, helping you stay compliant, build trust, and move faster with confidence. At Azpirantz, we go beyond checklists. We empower your teams with the frameworks, tools, and expertise to make privacy by design a real, repeatable practice, right from the start. Because at Azpirantz, we do not just secure data, we build digital trust. This content is created by the Azpirantz Marketing Team. READY TO ENHANCE YOUR DIGITAL RESILIENCE? Follow us for daily tips! *This content has been created and published by the Azpirantz M arketing Team and should not be considered a professional advice For expert consulting and professional advice, please reach out to sales@azpirantz.com