A Data Protection Impact Assessment (DPIA) is an analytical method for identifying and reducing, in advance, the risks that a processing activity may create for the rights and freedoms of individuals. While Turkey's KVKK does not set out a rigid rule with a specific article number saying "a DPIA is mandatory in the following case," carrying out a DPIA for high-risk processing is regarded as a strong good practice and a natural extension of the accountability principle. In this article we explain what a DPIA is, when it should be considered (with a decision tree), and how to run one with a step-by-step template.
What Is a DPIA and Why Do One?
A DPIA is a systematic risk analysis carried out before starting or significantly changing a processing activity. Its aim is to evaluate the type of data, the scope of processing and the potential harms, and to design appropriate measures from the outset. This approach aligns directly with the principle of privacy by design.
The main benefits of running a DPIA:
- Lets you see risks before a problem arises
- Backs accountability with documentation
- Enables cheaper solutions at the design stage
- Increases the trust of the individuals concerned
When Should It Be Considered? High-Risk Indicators
A DPIA is not needed for every processing operation; it is meaningful mainly for high-risk activities. If one or more of the following indicators is present, you should seriously consider running a DPIA:
- Large-scale processing of special categories of personal data (health, biometric data, religion, sex life, etc.)
- Systematic monitoring (for example, continuous camera surveillance of public areas)
- Use of new technologies (profiling with AI, facial recognition, and the like)
- Large-scale processing or matching of datasets
- Processing data of vulnerable groups (children, employees)
- Automated decisions with a significant effect on individuals
Decision Tree: Should I Run a DPIA?
The following decision tree offers a quick initial assessment:
- Are you starting a new processing activity or significantly changing an existing one? If no, a DPIA is not a priority; if yes, continue.
- Is at least one of the high-risk indicators above present? If no, a brief risk note may suffice; if yes, continue.
- Could the processing have a serious effect on individuals (loss of rights, discrimination, material harm)? If yes, run a DPIA; if unsure, run one anyway.
- Can measures be defined that bring the risks to an acceptable level? If no, obtain expert input and, if needed, redesign the activity.
How to Run a DPIA: Step-by-Step Template
The following steps provide a workable DPIA template:
- Describe the processing: which data, for what purpose, with what tools and for how long?
- Assess necessity and proportionality: could this purpose be achieved with less data?
- Identify the risks: list the potential harms to individuals (privacy breach, discrimination, financial loss).
- Rate the risks: score each risk's likelihood and impact as low/medium/high.
- Define measures: set technical and administrative safeguards (encryption, access restriction, anonymisation) for each risk.
- Assess residual risk: is the risk remaining after the measures acceptable?
- Document and review: record the decisions in writing and update them at regular intervals.
The table below is an example of a simple risk-assessment matrix:
| Risk | Likelihood | Impact | Priority | Measure |
|---|---|---|---|---|
| Excessive data collection | High | Medium | High | Data minimisation |
| Wrong automated decision | Low | High | Medium | Human oversight |
Example Scenario
A retail chain plans to count visitors to its stores using facial-recognition technology to estimate age and gender. This scenario contains several high-risk indicators: potential biometric data processing, systematic monitoring and use of new technology.
The decision tree clearly points to a DPIA here. As a result of the DPIA, the company decides to switch to a design that produces anonymous statistics instead of real-time identification, counting instantaneously without storing any images. This preserves the business goal while bringing the risk to individuals down to an acceptable level.
Frequently Asked Questions
Is a DPIA mandatory under the KVKK?
The KVKK does not set out a DPIA as an obligation named under a specific article number. However, running a DPIA for high-risk processing is a strong good practice that supports the accountability principle and is recommended.
Who should carry out the DPIA?
The DPIA is the controller's responsibility. In practice, the healthiest results come from a multidisciplinary team where technical, legal and business units work together.
Is a DPIA done once and finished?
No. A DPIA is a living document. It should be reviewed whenever the processing activity, the technology used or the level of risk changes.
Should a small business run a DPIA too?
It is the risk level of the processing, not the size of the business, that is decisive. Even a small business should consider a DPIA if it carries out high-risk processing.
This content is for general information only and does not constitute legal advice.
To identify your high-risk processing activities and manage your DPIA processes from a single dashboard, you can request a JUS. demo.