Data Protection · DPIA
What a DPIA is, when the GDPR requires one, the eight steps and a template, and how it shapes what you build.
Last updated: October 2026. Written by Athar Ahmad, Certified Bubble.io Developer and Tech Architect, Simple Automation Solutions.
Quick answer
A data protection impact assessment (DPIA) is a structured process for identifying and reducing the privacy risks of a planned use of personal data before it starts. The GDPR and UK GDPR require one where processing is likely to result in high risk, such as large-scale special category data, extensive profiling with significant effects or large-scale systematic monitoring, and regulators publish further lists. A DPIA describes the processing, assesses necessity, identifies risks, defines measures, records the outcome and is reviewed when things change.
Key takeaways
- A DPIA is required for likely high-risk processing; check your regulator’s list.
- Steps: describe, assess necessity, identify and evaluate risks, define measures, record, consult if needed, review.
- It often leads to collecting less data, restricting access, logging or human review.
- Do it before building, not after.
- General information; involve a data protection specialist.
In this guide
This guide is general information, not legal advice. Requirements differ by country and sector, so take advice from a qualified adviser.
What is a data protection impact assessment?
A data protection impact assessment, or DPIA, is a structured process for identifying and reducing the privacy risks of a planned use of personal data, before it starts. It is a requirement under the GDPR and UK GDPR for processing that is likely to result in a high risk to individuals’ rights and freedoms, and good practice for many other projects.
When is a DPIA required?
The GDPR requires one where processing is likely to be high risk, in particular for:
- Systematic and extensive evaluation of people based on automated processing, including profiling, where decisions with legal or similarly significant effects follow.
- Large-scale processing of special category data, such as health data, or of criminal offence data.
- Systematic monitoring of publicly accessible areas on a large scale.
Regulators also publish lists of other processing types that require a DPIA, for example using new technologies in ways that may be high risk, or combining datasets. Check your regulator’s list. Many organisations do a DPIA for any project involving sensitive data or new technology, such as AI applied to client information, as a matter of good practice.
Examples that may trigger one
| Project | Why it may be high risk |
|---|---|
| A clinic app holding patient records at scale | Special category health data |
| An AI tool that analyses client files | New technology applied to confidential data, possible profiling |
| A system that scores individuals automatically | Automated evaluation with significant effects |
| A portal handling financial or identity documents for many clients | Sensitive data at scale |
| Monitoring employee behaviour in detail | Systematic monitoring of individuals |
A small, ordinary client portal handling routine business data may not require one, but a short assessment is still a useful discipline.
What does a DPIA contain?
| Step | What you do |
|---|---|
| 1. Describe the processing | What data, whose, for what purpose, how it flows, who has access and how long it is kept |
| 2. Assess necessity and proportionality | Is each data item needed? Is there a lawful basis? Could less be collected? |
| 3. Identify risks to individuals | What could go wrong for them: unauthorised access, misuse, inaccuracy, loss, discrimination, loss of control |
| 4. Evaluate likelihood and severity | How probable and how serious is each risk? |
| 5. Identify measures | Technical and organisational ways to reduce each risk |
| 6. Record the outcome | Residual risk, decisions, who signed off and when |
| 7. Consult if needed | If high risk remains, consult the regulator before starting, where the law requires |
| 8. Review | Revisit when the processing changes |
Simple DPIA template
DPIA record
Project: ________ Owner: ________ Date: ________
What we are doing and why: ________
Data and people involved: ________
Lawful basis and necessity: ________
Who has access and where data is stored: ________
Retention: ________
Risks (with likelihood and severity): ________
Measures to reduce risk: ________
Residual risk and decision: ________
Sign-off and review date: ________
How does a DPIA affect what you build?
A DPIA often leads to design changes: collecting less data, restricting access, adding logging, shortening retention, adding human review for automated decisions or choosing a different supplier. That is the point. Doing it before building is far cheaper than after. See our security guide, database design mistakes and our thinking on AI features that keep a person in the loop.
What mistakes should you avoid?
- Treating it as paperwork after the decision is made.
- Writing it without involving the people who understand the system.
- Ignoring suppliers and where data flows.
- Recording risks but no measures.
- Never reviewing it when the project changes.
- Assuming a platform’s compliance replaces your own assessment.
At Simple Automation Solutions, builds start at $3,500, and a $345 Discovery Sprint, credited toward the build, captures the data, roles and risks you will need for a DPIA. We do not conduct legal assessments, and recommend your data protection adviser leads it.
Frequently asked questions
What is a DPIA?
A data protection impact assessment: a structured process to identify and reduce the privacy risks of a planned use of personal data before it starts.
When is a DPIA mandatory?
Under the GDPR and UK GDPR, where processing is likely to result in high risk, such as large-scale special category data, extensive profiling with significant effects or large-scale systematic monitoring. Regulators publish further lists.
Do I need a DPIA for a client portal?
A routine portal may not require one, but if it handles sensitive data at scale or uses new technology such as AI, check the rules and consider one.
Who should complete a DPIA?
The project owner, with input from people who understand the system and advice from a data protection specialist.
What happens if a DPIA shows high residual risk?
You may need to change the design, or consult the regulator before starting, where the law requires.
Planning a system that handles sensitive data?
Email us what it will hold and who will use it. We will capture the data, access and risk information you will need.
Athar Ahmad, Certified Bubble.io Developer and Tech Architect, Simple Automation Solutions
About Simple Automation Solutions (SA Solutions)
Simple Automation Solutions is a Bubble.io development studio led by Athar Ahmad, a Certified Bubble.io Developer and Tech Architect. It builds web and mobile apps, client portals and SaaS products for founder-led businesses such as law firms, accounting firms, boutique agencies and consultants. Services include a free 30-minute Idea Audit, a $345 Discovery Sprint (a Product Requirements Document delivered within 24 hours, credited toward the build) and builds starting at $3,500. Website: sasolutionspk.com.
