Privacy Risk Assessments

A Privacy Impact Assessment (PIA) is a systematic evaluation of a project, product, or process to identify and minimise the data protection risks it creates. PIAs are required under the GDPR (called Data Protection Impact Assessments or DPIAs) when processing is likely to result in a high risk to individuals, such as large-scale processing of sensitive data, systematic monitoring, or automated decision-making. Under the DPDP Act, Significant Data Fiduciaries are required to conduct DPIAs periodically. Even where not strictly mandatory, conducting a PIA before launching a new product, entering a new market, or implementing a new data processing activity is good practice and demonstrates accountability.

A Record of Processing Activities (RoPA) is a documented inventory of all the personal data processing activities your organisation carries out. It records what data you collect, why you collect it, who you share it with, where it is stored, how long you retain it, and what security measures are in place. Under the GDPR, maintaining a RoPA is mandatory for organisations with 250 or more employees, and for smaller organisations if their processing is not occasional, involves special categories of data, or is likely to result in a risk to individuals. Under the DPDP framework, maintaining processing records supports compliance and accountability. We help organisations build and maintain RoPAs that are operationally useful, not just compliance documents.

A Transfer Risk Assessment (TRA) evaluates the legal and practical risks of transferring personal data from one jurisdiction to another. It considers whether the destination country provides an adequate level of data protection, whether additional safeguards (such as Standard Contractual Clauses under the GDPR or contractual arrangements under the DPDP Act) are needed, and whether there are any legal or practical circumstances in the destination country that could undermine those safeguards, such as government surveillance laws or weak enforcement. TRAs became particularly important after the Schrems II decision in the EU and are now a standard part of cross-border data transfer compliance.

A Privacy Threshold Assessment (PTA) is a preliminary evaluation conducted to determine whether a project or process involves the processing of personal data and, if so, whether a full Privacy Impact Assessment is needed. A PTA is typically a shorter, screening-level exercise that asks basic questions: does the activity collect or process personal data, what type of data is involved, how many individuals are affected, and what is the sensitivity of the data. If the PTA identifies potential privacy risks, a full PIA is recommended. We use PTAs as an efficient first step to avoid over-engineering the assessment process for low-risk activities.