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Running a data protection impact assessment

How a company starts an impact assessment before high-risk work begins, scores it, promises and records fixes, consults people, and has it signed off by someone independent.

Updated

An impact assessment is written before work that could materially affect people begins, while not doing it is still a choice. Each assessment on Asiri carries two figures: the risk before anything was done, and the risk that remains after the fixes.

Who can do this

An owner, editor or contributor of your workspace can start, score and work on an assessment. Signing one off has to be done by someone who did not write it and did not complete any of its fixes. A viewer can read the register.

Find the register

Open Records & controls → Impact assessments. The tabs include In flight, Waiting on you, High after fixes and Signed off. From the top of the page you can open Templates, Approvals and Fixes, or press Start an assessment.

Start an assessment

Press Start an assessment, or open Templates and press Start from this on one that fits. A template saves the first hour, not the work. If it ticks a circumstance that does not apply, untick it.

  1. Under Assessment details, give What to call it, What it does, in a sentence and When it is meant to launch.
  2. Under Purpose, tick what the work is for.
  3. Under Mandatory circumstances, tick each circumstance from GAID 2025 Article 29 that applies. Any one of them makes the assessment mandatory.
  4. Under Additional risk factors, tick what else raises the risk. These are Asiri's own judgement and cannot make an assessment mandatory.

Press Start the assessment. It is saved as a draft.

Score it

On the assessment, press Score this assessment. Tick Which of the Directive’s circumstances apply and the Other risk factors, write Why this is the score, and press Record the score.

If nothing is ticked, the assessment stays not scored. Not scored is not low. Until it is scored, the record cannot say what the Commission needs.

Promise and record the fixes

Under What is being done about it, press Promise a fix. Say What will be done, Who does it and the date under Done by, then press Promise the fix. A fix with no date is never overdue, and never scheduled either.

When a fix has happened, open Fixes and use Record that one is done: give the Assessment reference, choose Which promised fix, set the Fix state to Done or Independently checked, write the Recorded reason, and press Record fix. A fix cannot be checked by the person who owns it.

The risk that remains is a claim that the fixes were done. If the fixes moved nothing, the record says so.

Consult people

Press Record a consultation. Give Who was consulted and What they said, then press Record consultation. You can record that someone was asked even if they gave no written response. An entry is never edited. Use Correct this entry or Withdraw it, with a reason, and the earlier version stays readable.

The Commission

The record shows one of Not determined yet, Consult before launch, File with the Commission or Not needed, read from the score.

  • Consult before launch: the consultation sets the date the work can go live. Internal sign-off does not.
  • File with the Commission: once it is filed, write Where it was filed, such as the acknowledgement number, and press Record the filing.

Sign-off

Someone other than the author opens Approvals. Under Impact assessment, they give the Assessment reference and an Approval reason, and press Approve assessment. Asiri refuses an approval from the author or from anyone who completed one of its fixes. Assessments waiting on you lists what is waiting, and anything that stops sign-off.

Common questions

"Can we assess work that has already launched?" You can record it, but an assessment written after launch is a description. Start before.

"Why is the score not a single number?" The risk before and the risk that remains are shown separately, so you can see whether the fixes changed anything.

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