Chapter 8: Data Protection Impact Assessments (DPIAs)

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Questions and Answers

Which of the following is NOT a method used by the DPIA Project Team to assess IT systems or processes?

  • Analyzing the potential impact and likelihood of risks
  • Conducting random audits of employee behavior (correct)
  • Identifying areas in the data flow that could lead to compliance failures
  • Creating a DPIA checklist/questionnaire

What are the purposes for which personal data is collected, used, and disclosed required to be?

  • Secret to protect individual privacy
  • Unrestricted and flexible to accommodate data trends
  • Customizable for personal discretion by data handlers
  • Documented and considered reasonable (correct)

What is a key consideration for the DPIA Project Team when assessing data protection risks?

  • The technology used in competitor companies
  • The number of data subjects affected
  • The implementation of a real-time monitoring system
  • The specific circumstances of the organization (correct)

What should the action plan created by the DPIA Project Team leader address? (Select all that apply)

<p>Provide a mechanism for monitoring plan implementation outcomes and implementation timelines (B), As a good practice, provide a contact point for responding to queries regarding the DPIA process and/or implementation of the action plan (C), Indicate the action owner(s) responsible for the implementation of specific recommendations (such as technical and organisational measures) (A)</p> Signup and view all the answers

Why is there no 'one-size-fits-all' method for identifying data protection risks?

<p>Because systems and processes vary significantly across different types and stages (C)</p> Signup and view all the answers

What is one factor organizations should consider when determining the likely adverse effect on an individual due to personal data handling?

<p>The nature and type of personal data involved (C)</p> Signup and view all the answers

Which of the following constitutes a measure organizations may implement to mitigate adverse effects on individuals?

<p>Encrypting personal data before processing (B)</p> Signup and view all the answers

Why may some differential charges not be considered as having an adverse effect on individuals?

<p>They result from legitimate assessments of risk (e.g. insurance premiums) (A)</p> Signup and view all the answers

What is deemed inappropriate for organizations if there are likely residual adverse effects after implementing protective measures?

<p>Using deemed consent by notification (A)</p> Signup and view all the answers

Which of the following describes a vulnerable segment of the population that organizations should consider?

<p>Individuals with limited access to technology (A)</p> Signup and view all the answers

What is an example of a potentially negative outcome from the collection or use of personal data?

<p>Physical harm to individuals (C)</p> Signup and view all the answers

Under which circumstances must an organization conduct a DPIA according to the outlined regulations?

<p>An existing IT system or process that the organisation is reviewing or substantially redesigning for collecting, using, disclosing and storing personal data (@), A new IT system or process that the organisation is introducing, developing or implementing, such as a new IT system or a new manual process for collecting, using, disclosing and storing personal data (B)</p> Signup and view all the answers

What type of IT process change requires a DPIA?

<p>A significant redesign of an existing process that handles personal data. (B)</p> Signup and view all the answers

What is a scenario that would typically require a DPIA?

<p>A clinic implements a new system to track patient personal data. (C)</p> Signup and view all the answers

How should organizations view the introduction of new technology regarding DPIA?

<p>Only intrusive technologies, like facial recognition, require consideration. (A)</p> Signup and view all the answers

What action must an organization take if using personal data for new purposes?

<p>Ensure that the new purpose aligns with previously obtained consents. (D)</p> Signup and view all the answers

Which of the following is NOT a factor to assess in a DPIA?

<p>Whether the organization will benefit financially from the data processing. (B)</p> Signup and view all the answers

In what situation would a DPIA not be necessary for existing processes?

<p>The process has been recently reviewed with no changes. (A)</p> Signup and view all the answers

Which situation requires a reassessment of the need for a DPIA?

<p>When there's a change in risks associated with data handling (D)</p> Signup and view all the answers

Who typically is NOT included in the DPIA Project Team?

<p>Legal counsel from another organization (D)</p> Signup and view all the answers

After assessing and concluding the need for a DPIA, the members of the DPIA Team are formed, including other organisational functions or departments that have some level of involvement in the project, external parties such as subject matter experts or even potentially affected individuals,where needed. Who else should be on the DPIA Team?

<p>Project manager (A), DPO (C), DPIA Steering committee (D)</p> Signup and view all the answers

Who typically does NOT have a role in the DPIA process?

<p>Financial analysts unrelated to the project (D)</p> Signup and view all the answers

What type of data is considered sensitive personal data?

<p>Health records and financial records (D)</p> Signup and view all the answers

What must an organization do if it has been established that a DPIA needed?

<p>Form a DPIA Project Team (B)</p> Signup and view all the answers

Which role is generally included in a DPIA Project Team?

<p>Data Protection Officer (D)</p> Signup and view all the answers

What kind of changes should prompt a new assessment for a DPIA?

<p>Change in technology infrastructure (D)</p> Signup and view all the answers

What is a key function of the DPIA steering committee?

<p>To guide the DPIA process and ensure compliance (C)</p> Signup and view all the answers

What is the purpose of the project description in the DPIA plan?

<p>To provide an overview and rationale for the DPIA. (D)</p> Signup and view all the answers

Which component of the DPIA focuses on specific IT systems or processes?

<p>Scope of the DPIA. (B)</p> Signup and view all the answers

What is essential to define within the risk assessment framework of a DPIA?

<p>The methods for calculating risk and assessment criteria. (C)</p> Signup and view all the answers

Who should be identified in the 'parties involved' section of a DPIA?

<p>Internal departments and external stakeholders relevant to the project. (C)</p> Signup and view all the answers

What aspect is covered in the DPIA timeline?

<p>An estimate of the time for key tasks and the total duration required. (C)</p> Signup and view all the answers

Why is it important to explain why a DPIA is needed in the project description?

<p>To clarify the necessity and relevance of the DPIA to stakeholders. (B)</p> Signup and view all the answers

What should be included in the detailed description of the IT system or process in the scope of the DPIA?

<p>Technical specifications and data management practices. (A)</p> Signup and view all the answers

What is a key consideration to address when determining the risk assessment criteria?

<p>The magnitude and likelihood of risks occurring. (C)</p> Signup and view all the answers

How should the input from relevant parties be sought during a DPIA?

<p>By conducting structured interviews or consultations. (D)</p> Signup and view all the answers

What role does the DPIA timeline play in the DPIA process?

<p>It serves as a schedule for project milestones and tasks. (D)</p> Signup and view all the answers

What is the correct order of the life-cycle sequence of a Data Protection Impact Assessment (DPIA)?

<p>1 – Assess the need for a DPIA, 2 – Plan the DPIA, 3 – Identify the personal data and personal data flows, 4 – Identify and assess data protection risks, 5 – Create an action plan, 6 – Implement the action plan and monitor its results (A)</p> Signup and view all the answers

Why does an organization need to conduct a Data Protection Impact Assessment (DPIA)?

<p>To assess compliance with the PDPA and implement measures to safeguard personal data. (B)</p> Signup and view all the answers

An organisation could conduct a DPIA on which of the following: (Select all that apply)

<p>Purchasing an item from an online portal (i.e. its processes) (C), Customer Relationship anagement System (i.e. IT systems) (A)</p> Signup and view all the answers

According to the new provisions on deemed consent by notification and legitimate interests exception in the PDPA under section 15A of the PDPA read with oara 1 of Part 3 of the new First Schedule, organisations are required to undertake the following actions:

<p>Conduct a Data Protection Impact Assessment (DPIA) to identify any adverse effects that the proposed processing of personal data might have on individuals (B), Identify and implement reasonable measures to eliminate, reduce, or mitigate those adverse effects. (@)</p> Signup and view all the answers

What would PDPC consider as an 'adverse effect'?

<p>Physical harm or harassment, serious alarm or distress to the individual (A)</p> Signup and view all the answers

What are the key tasks in a DPIA? (Select all that apply)

<p>Identifying the personal data collected, used, disclosed, and stored by the IT system or process (A), Identifying data protection risks by analyzing the personal data against PDPA requirements (C), Checking to ensure that identified risks are adequately addressed before implementation (@), addressing the risks identified by changing IT systems and/or SOPs (@)</p> Signup and view all the answers

What are the elements in the plan for a DPIA? (Select all that apply)

<p>Project description (A), Parties involved (C), DPIA timeline (D), Scope of the DPIA (@), Risk assessment framework (@)</p> Signup and view all the answers

Phase 3 DPIA: How can the organization identify the personal data flows in the relevant IT system? (Select all that apply)

<p>Collating and reviewing documentation related to the relevant IT system or process to determine how the organization will collect, use, disclose and store personal data. (A), Consulting with the organization’s relevant departments and/or functions to ensure comprehensiveness and accuracy of the information gathered about the personal data and personal data flows. (B), Conducting an on-site inspection of the relevant IT system or process with ground personnel. (C)</p> Signup and view all the answers

What questions should be listed in the DPIA checklist/questionnaire (select all that apply)? (i) Is consent obtained from individuals for any collection, use and disclosure of their personal data? (ii) Are the purposes for which personal data is collected, used, and disclosed considered reasonable in the circumstances? (iii) Are the purposes for the collection, use, and disclosure of personal data documented? (iv) Will the appointed third party service providers use the personal data disclosed to them by the organisation only in line with the purpose(s) intended by the organisation?

<p>All of the above (D)</p> Signup and view all the answers

How can the DPIA Project Team identify and assess personal data risks? (Select all that apply)

<p>Create a DPIA checklist/questionnaire and use it to assess the relevant IT system or process against the requirements in the PDPA and/or data protection best practice. (A), Identify areas in the personal data flow that could lead to a failure to comply with the PDPA (for example, a loss of personal data) and areas that are gaps compared with industry best practice. (B), Analyze the potential impact and likelihood of identified gaps and risks based on the pre-defined risk framework. (C)</p> Signup and view all the answers

What is the final phase of a DPIA? (Select all that apply)

<p>Implement the action plan and monitor its results (A), Document the entire DPIA process (that is, how the DPIA was scoped, planned and carried out, its findings, and the proposed action plan) into a DPIA report. (B), Submit to the DPO for review, and Senior management for approval thereafter. (C)</p> Signup and view all the answers

Flashcards

Adverse Effect of Personal Data

When decisions based on personal data potentially cause harm or disadvantage to an individual.

Impact Assessment

This focuses on the potential impact on an individual from collecting, using, or disclosing their personal data.

Factors in Assessing Adverse Effects

The organization should consider factors like the type of data, the individual's vulnerability, and the extent of data use.

Reasonableness of Data Use

The organization needs to justify why they are collecting, using, or disclosing this personal data.

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Potential Harm from Data-Driven Decisions

This refers to possible harm, distress, or harassment caused by predictions or decisions derived from personal data.

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Mitigating Adverse Effects

Organizations should take steps to minimize or eliminate risks to individuals when using their personal data.

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Residual Adverse Effects

When risks remain even after taking measures to mitigate adverse effects, implied consent from individuals cannot be assumed for using their personal data.

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Sensitive Data System

The system/process that collects sensitive personal data, like health, criminal, or financial records, and is likely to raise concerns or expectations among individuals.

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Data Protection Impact Assessment (DPIA)

The process of evaluating the potential risks and impacts of collecting, using, disclosing, or storing personal data.

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DPIA Trigger

The organization determines that a system/process collects, uses, discloses, or stores personal data, but doesn't meet the necessary requirements for data protection.

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DPIA Project Team

A team responsible for conducting a DPIA, typically including a project manager, the Data Protection Officer (DPO), and other relevant individuals or departments.

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DPIA Steering Committee

A steering committee responsible for guiding and overseeing the DPIA process.

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Organizational Functions in DPIA

An organization's role within the DPIA framework. They need to identify potential risks and recommend mitigation strategies.

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Subject Matter Experts (SMEs) in DPIA

Individuals or groups who can provide specialized expertise or knowledge related to the DPIA.

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Involving Affected Individuals in DPIA

Involving affected individuals in the DPIA process to ensure their concerns and needs are addressed.

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Reassessing DPIA Need

The organization must reassess the need for a DPIA if changes occur in the risks associated with the data handling process.

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DPIA Plan

A comprehensive plan covering all steps and procedures for conducting the DPIA.

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When to Conduct a DPIA

An organization needs to conduct a Data Protection Impact Assessment (DPIA) when a new or existing IT system or process involves collecting, using, disclosing, or storing personal data, especially if it's a new system, a major redesign of an existing system, or involves new technology that may be intrusive.

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DPIA Triggers: What to Look For

A DPIA is required if the IT system or process involves collecting new personal data, disclosing personal data to new parties, using personal data for a purpose not currently used, or using data in a way that is not currently used, especially if the individual hasn't consented.

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Screening Questions for DPIA

Before deciding whether to conduct a DPIA, an organization can ask screening questions to spot potential risks. These questions help assess whether the IT system or process might involve new data collection, data disclosure to new parties, new data uses or methods without consent, or the use of intrusive technologies.

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Typical Screening Question Examples

Examples of screening questions include: Does the new or changed IT system or process involve collecting new personal data? Will there be new recipients of this data? Is the organization using personal data for a purpose not currently used or in a way not currently used without consent? Does the system involve new technology that could be intrusive to individuals?

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Purpose of a DPIA

A DPIA aims to analyze the potential adverse effects on individuals from collecting, using, and disclosing personal data. This includes assessing the potential harm, distress, or harassment, and the level of risk for individuals.

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Factors to Consider in a DPIA

The DPIA should consider factors like the type of personal data being used, the vulnerability of the individuals involved, the duration and extent of data use, the context of data use, and the potential for harm or misuse.

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Data Use Justifications in DPIA

A DPIA involves assessing whether the use of personal data is necessary and, if so, whether it's proportionate to the intended purpose and aligned with the principles of data minimization and good faith.

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Mitigating Risks in a DPIA

The DPIA should identify potential risks to individuals and consider appropriate measures to mitigate those risks. This could include steps like anonymization, data encryption, access controls, and data minimization.

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Residual Risks and Consent in DPIA

If a DPIA identifies residual risks that cannot be mitigated, the organization must consider obtaining explicit consent from individuals for the use of their personal data. Implied consent may not be sufficient in such cases.

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DPIA Checklist/Questionnaire

This is a structured evaluation tool used to assess the impact of collecting, using, disclosing, or storing personal data. It helps determine potential risks from different data handling processes and ensures compliance with data protection regulations.

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Identifying Potential Non-Compliance Areas

This focuses on identifying areas within the system or process where data might be used in ways that fail to comply with data protection rules. This could involve inadequate data security measures, incomplete data processing processes, or potential for misuse of data.

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Analyzing Impact & Likelihood of Risks

This involves analyzing the potential impact of identified risks and gaps based on a pre-defined framework, considering the likelihood of these risks materializing. This helps in prioritizing risks and determining the severity of the data protection risks.

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DPIA Action Plan

This is the next phase of the DPIA process where the organization creates a plan to address the identified data protection risks. It outlines the steps for mitigating risks, improving data security, and ensuring compliance with regulations.

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Considering Specific Circumstances

This involves considering specific factors that influence a system or process's data protection risk, such as the type of data handled, the sensitivity of the information, and the number of individuals affected. It helps to tailor the DPIA to the organization's unique circumstances.

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Project Description in a DPIA

A detailed description of the project's purpose, timeline, and relevant departments or functions involved.

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Justification for DPIA

Explains why a DPIA is necessary for the project, focusing on the potential risks involved in processing personal data.

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DPIA Key Considerations

Outlines key considerations surrounding the DPIA, such as any specific legal or ethical challenges related to the project.

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Scope of the DPIA

Clearly defines the specific IT system or process that the DPIA will focus on, including its purpose and how personal data is processed.

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Risk Assessment Framework

Establishes the criteria for assessing risks and describes the methods used to calculate the likelihood and impact of potential data breaches.

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Parties Involved in DPIA

Identifies internal teams (e.g., IT, Legal) or external parties (e.g., consultants, regulators) involved in the DPIA.

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Gathering Stakeholder Input

Describes how input and feedback will be gathered from stakeholders, such as interviews, surveys, or workshops.

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DPIA Timeline

Provides estimated timings for key tasks and the overall timeline for completing the DPIA.

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Data Processing Activities

Includes a detailed explanation of the data processing activities covered by the DPIA, including the purpose, legal basis, and data subjects involved.

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Impacts on Individuals

Evaluates the potential impacts of data processing activities on individuals, including the potential for harm, discrimination, or violation of rights.

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Study Notes

Data Protection Impact Assessments (DPIAs)

  • DPIAs are about conducting a Data Protection Impact Assessment.
  • A Data Protection Impact Assessment (DPIA) involves identifying, assessing, and addressing personal data protection risks based on an organization's functions, needs, and processes.
  • An organization conducting a DPIA would be better positioned to evaluate whether their handling of personal data complies with PDPA regulations or best practices and implement the necessary technical or organizational measures to safeguard against data protection risks to individuals.
  • An organization could conduct a DPIA on:
    • IT systems (e.g., websites, cloud storage, CRM systems)
    • Processes (e.g., health screenings, online purchases)
  • Organizations should conduct a DPIA for:
    • New IT systems or processes
    • Existing IT systems or processes undergoing changes
  • Assessments under PDPA require organizations to assess the impact of processing personal data when relying on deemed consent or legitimate interests exceptions.
  • Assessments should identify any potential adverse effects on individuals and implement reasonable measures to eliminate, reduce, or mitigate these effects.
  • Adverse effects include physical harm, harassment, serious alarm, or distress.
  • When determining the likely effect on an individual, the organization should consider factors such as the nature and type of personal data, the vulnerability of individuals, the extent and processing specifics of the data, the purpose of collection/use/disclosure and whether the predictions or decisions based on the data could cause harm.
  • Reasonable measures include data minimization, encryption, functional separation, access controls, and other technical or organizational measures to reduce risks.
  • When residual adverse effects remain after implementing measures, organizations relying on deemed consent can't collect data, and those relying on legitimate interests must balance the organization's legitimate interests against any likely residual adverse effect on the individual.
  • Key tasks in a DPIA include identifying personal data collected, used, disclosed, and stored; tracing how personal data flows; identifying data protection risks based on data flows and regulations; and addressing identified risks by amending designs, introducing policies, or practicing procedures.
  • A DPIA involves a life-cycle, including assessing the need, planning, identifying personally identifiable information (PII) and data flows, identifying and assessing risks, creating an action plan, and monitoring results.
  • Organisations should consult with stakeholders (both internal and external, such as employees, volunteers, third party providers.) throughout the DPIA to ensure buy-in and support for the process.
  • A DPIA project team should be present during the assessment process (such as a project manager, DPO, DPIA steering committee, involved departments, and subject-matter experts).

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