Privacy Impact Assessment Template - Free Download & Example

A Privacy Impact Assessment (PIA), referred to in GDPR terminology as a Data Protection Impact Assessment (DPIA), is a systematic analysis of how your project or system processes personal data and what risks this poses to the data subjects. Since the GDPR came into force in 2018 a DPIA is mandatory when processing is likely to result in a high risk to the rights and freedoms of natural persons. This includes large-scale processing of special categories of personal data, systematic monitoring of publicly accessible areas and automated decision-making with legal effects. This template guides you through the complete DPIA process: description of the intended data processing with purposes and legal basis, a data inventory of all personal data processed including source, storage location and retention period, a necessity and proportionality test, a risk analysis from the perspective of the data subject with likelihood and impact per risk, and an overview of measures to mitigate identified risks to an acceptable level. The result is a documented justification of your compliance that you can present to the Data Protection Authority. The template also accounts for the requirements of the NIS2 directive that came into force in 2024 and imposes additional obligations on organisations in essential and important sectors. For organisations working with AI systems the template includes supplementary sections addressing the EU AI Act, enabling you to systematically map the privacy aspects of automated decision-making. The template also includes a section for documenting data breach procedures and notification obligations so you know exactly which steps to follow in case of a breach and which authorities must be informed within which timeframe.

Variations

How to use

Step 1: Download the PIA template and determine whether a full DPIA is legally required for your project. Consult the list of processing operations for which the Data Protection Authority mandates a DPIA. When in doubt, performing a DPIA is always recommended as good privacy practice. Step 2: Describe the intended data processing in detail: what is the purpose of processing, which legal basis do you use (consent, contract, legitimate interest, legal obligation), who are the data subjects and which categories of personal data are processed? Step 3: Create a complete data inventory. List per data element: the data type, source (directly from data subject, from third party, generated), storage location, retention period, who has access and whether the data is shared with third parties. Step 4: Perform the necessity and proportionality test. Ask yourself: are all collected data truly necessary for the described purpose? Can the purpose also be achieved with less data or anonymised data? Is the processing proportional given the impact on the privacy of data subjects? Step 5: Identify risks from the perspective of the data subject, not from the perspective of the organisation. Consider: unauthorised access to data, unintended disclosure, discrimination through automated decision-making, unlawful profiling and inability to exercise privacy rights. Step 6: Assess per risk the likelihood (high, medium, low) and impact (severe, limited, minimal) and calculate the risk level. Step 7: Describe per identified risk the measures you take to mitigate it: encryption, pseudonymisation, access control, data minimisation, retention periods, data processing agreements, security audits and privacy by design in the architecture. Step 8: Document the residual risk after mitigation and determine whether it is acceptable. If the residual risk remains high, consult the Data Protection Authority before starting the processing. Step 9: Schedule an annual DPIA review and link it to your release calendar, so significant changes in processing automatically trigger a reassessment. Document per review what has changed compared to the previous version and what impact this has on the risk profile. Step 10: Communicate the DPIA outcomes to all involved teams, including development, product and support. Ensure developers understand which technical privacy measures they need to implement and why, so privacy awareness becomes part of daily development practice rather than a one-time compliance exercise. Step 11: Document the legal basis for each processing activity in accordance with GDPR. Describe per data collection whether processing is based on consent, contractual necessity, legal obligation or legitimate interest. Step 12: Add a retention policy describing per category of personal data how long data is retained and how deletion is guaranteed after the retention period expires, including technical measures for automated data cleanup.

How MG Software can help

MG Software integrates privacy by design as a core principle in every software development project. Our developers and architects are trained in applying data minimisation, encryption and access control at the architecture level. We help you perform DPIA assessments, implement technical privacy measures and set up data governance processes aligned with GDPR requirements. By addressing privacy early in the development process you avoid costly retroactive adjustments. Specifically we support you in creating processing registers, evaluating third-party processors and implementing technical measures such as automatic data retention with deletion, consent management and audit logging that meet the requirements of the Data Protection Authority. Our team has experience with DPIA trajectories across sectors including fintech, healthcare and e-commerce, and understands the specific risk profiles and compliance requirements per industry. We also facilitate the conversation with your Data Protection Officer and legal adviser, ensuring the technical implementation seamlessly aligns with the legal framework and no gaps emerge between policy and practice.