Which scenario most likely triggers a data privacy impact assessment (DPIA)?

Which scenario most likely triggers a data privacy impact assessment (DPIA)?

• A. Processing routine administrative data with minimal risk.
• B. Processing large-scale sensitive health data for a new digital health platform.
• C. Publishing anonymized summary statistics.
• D. Transferring data within a single department with no external sharing.

Answer: (B)

A DPIA is prompted when processing could pose a high risk to individuals’ privacy, especially for large-scale data or when new technologies change how data is handled. Processing large-scale sensitive health data for a new digital health platform clearly fits that pattern: health data is a protected, “special category” and handling it at scale increases the potential impact of any misuse or breach. The introduction of a new platform adds uncertainty about data flows, access controls, retention, and purposes, making a privacy risk assessment essential to identify and mitigate risks before deployment. In the other scenarios, the privacy risks are typically lower: routine administrative data with minimal risk is unlikely to trigger a DPIA; publishing anonymized statistics reduces identifiability, so a DPIA isn’t usually required; and transferring data within a single department with no external sharing generally poses fewer external privacy risks, assuming governance and minimization are strong.

A DPIA is prompted when processing could pose a high risk to individuals’ privacy, especially for large-scale data or when new technologies change how data is handled. Processing large-scale sensitive health data for a new digital health platform clearly fits that pattern: health data is a protected, “special category” and handling it at scale increases the potential impact of any misuse or breach. The introduction of a new platform adds uncertainty about data flows, access controls, retention, and purposes, making a privacy risk assessment essential to identify and mitigate risks before deployment.

In the other scenarios, the privacy risks are typically lower: routine administrative data with minimal risk is unlikely to trigger a DPIA; publishing anonymized statistics reduces identifiability, so a DPIA isn’t usually required; and transferring data within a single department with no external sharing generally poses fewer external privacy risks, assuming governance and minimization are strong.