DPIA template (data protection impact assessment)

A data protection impact assessment (DPIA) checks a planned use of personal data for risks to the people it's about, before it starts, and records how you'll reduce them. This free Word template follows the seven steps of the ICO's DPIA guidance and its sample template, from screening to sign-off.

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Under UK GDPR a DPIA is compulsory when processing is likely to result in a high risk to people's rights and freedoms. Step 1 screens for that, so you can show why you did one or didn't.

What's in the template

Data protection impact assessment (DPIA)

Project 
Controller 
DPIA owner 
Data protection officerName, or 'none' and who advised instead
Version and date 

Step 1: Identify the need for a DPIA

Describe the project. A DPIA is required if anything in list A applies, or anything in list B plus anything in list C.

List A

  • Automated evaluation or profiling behind decisions with legal or similar effects
  • Large-scale special category or criminal offence data
  • Large-scale systematic monitoring of a public area
  • Automated decisions or special category data deciding access to products, services, opportunities or benefits
  • Large-scale profiling
  • Matching or combining data from several sources
  • Children's or vulnerable people's data used for marketing, profiling or automated decisions; online services offered directly to children
  • A breach could endanger physical health or safety

List B

  • New technology, or a novel use of existing technology
  • Biometric data used to identify people
  • Genetic data, unless a GP or health professional is providing care
  • Data not obtained from the people, where telling them is impossible or disproportionate
  • Tracking location or behaviour

List C (two or more usually call for a DPIA on their own)

  • Evaluation or scoring
  • Automated decisions with legal or similar effects
  • Systematic monitoring
  • Sensitive or highly personal data
  • Large scale
  • Matching or combining datasets
  • Vulnerable people
  • Innovative technology
  • Blocks a right, service or contract
Outcome and reasons 
Decided by and date 

Step 2: Describe the processing

NatureHow data is collected, used, stored, shared and deleted
ScopeWhat data, how much, how long, how many people
ContextPeople's expectations and control; vulnerable groups; anything novel
PurposesAims, benefits and effect on people

Step 3: Consultation

WhoHow and whenViews and changes made
People affected or their representatives  
Information security  
Processors  
DPO or data protection lead  

Step 4: Necessity and proportionality

Lawful basis and any special category condition 
Achieves the purpose? Less intrusive option? 
Function creep, minimisation and accuracy 
Information for people; their rights 
Processors; international transfers 

Step 5: Identify and assess risks

Likelihood: remote, possible or probable. Severity: minimal, significant or severe. Overall: low, medium or high.

Risk to individualsLikelihoodSeverityOverall
    
    
    

Step 6: Identify measures to reduce risk

RiskMeasureEffect: eliminated, reduced or acceptedResidual riskApproved?
     
     
     

Step 7: Sign off and record outcomes

ItemName, position, dateNotes
Measures approved by Actions added to the project plan
Residual risks approved by High risk left: consult the ICO first
DPO advice Summary; reasons if overruled
Consultation responses reviewed by Reasons if departing from people's views
Review owner Next review date

When a DPIA is required

UK GDPR, Article 35. You must assess processing that is likely to result in a high risk to people's rights and freedoms before it starts. Three cases always qualify: automated evaluation or profiling behind decisions with legal or similarly significant effects; large-scale special category or criminal offence data; and large-scale systematic monitoring of a publicly accessible area.

The ICO's list. Five of its ten types need a DPIA on their own (list A). The other five, including tracking and biometrics, need one when combined with any of the nine screening criteria from the European guidelines (list C). Two criteria together usually point to one as well. If you decide against a DPIA, record why. The ICO is reviewing this guidance after the Data (Use and Access) Act 2025.

How to carry out a DPIA

  1. Screen at the idea stage, before choosing a supplier; the ICO expects a DPIA to run alongside planning.
  2. Map the data from collection to deletion: sources, systems, access, sharing.
  3. Consult the people affected or their representatives unless there's a good reason not to (record it), plus whoever handles information security.
  4. Challenge the need. Record the less intrusive options and why each falls short.
  5. Score harm to people, not the company: intrusion, unfair decisions, discrimination, financial loss, distress. A significant chance of very serious harm can make a risk high.
  6. Sign off. If you have a DPO you must seek their advice; record it, and why if you overrule it.
  7. Consult the ICO if a high risk remains, and don't start until you have; it says it replies within eight weeks, or 14 if complex. Then add the actions to your project plan.

Example: van tracking at a fictional 80-person courier firm

A fictional courier plans telematics and dashcams for its 50 vans. Tracking drivers, combined with systematic monitoring and scoring of their driving, meets the ICO's test. From steps 5 and 6:

Risk to individualsLikelihoodSeverityOverallMeasure agreedResidual
Location reveals drivers' breaks and off-shift tripsProbableSignificantHighPrivate mode outside shifts; break stops hiddenLow
Driving scores used for warnings without contextPossibleSignificantMediumScores discussed with the driver before any actionLow
Driver-facing camera recording all dayProbableSevereHighDropped: road-facing cameras onlyNone
Supplier breach exposes journey historiesPossibleSignificantMediumProcessor contract; multi-factor sign-in; 12 months' historyLow

Drivers objected to the in-cab camera at depot briefings, so it was dropped. With no high risk left, no ICO consultation was needed.

Common mistakes

  • Starting after the contract is signed, when the DPIA can only justify decisions already made.
  • Listing only security threats. Unfairness and intrusion into private life count too.
  • Never reopening it. The ICO calls a DPIA a living process.

Frequently asked questions

Is a DPIA mandatory?

Only when processing is likely to be high risk: the three Article 35(3) cases and anything meeting the ICO's list. Otherwise it's optional, though the ICO recommends one if you're unsure. Standing rules belong in a data protection policy.

Do we have to publish our DPIA?

No. The ICO calls publishing good practice, not a duty; leave out security details that could help an attacker.

What if we skip a DPIA we needed?

The ICO says failing to carry out a required DPIA can lead to enforcement action, including a fine of up to £8.7 million.

The template follows the ICO's structure, but it isn't legal advice.

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