Carrying out a data protection impact assessment before: Before | AIGP
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Carrying out a data protection impact assessment before: Before deployment, which GDPR controller obligation

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Medium

Large-scale, significant automated profiling likely to be high risk requires a DPIA before the processing starts.

The question

A bank plans to deploy a new AI system that performs systematic, large-scale profiling of applicants to make decisions with significant effects on them. Before deployment, which GDPR controller obligation is most directly triggered?

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  1. Entering into a standard contractual clause arrangement to cover any transfer of data outside the region
    Plausible, but transfer safeguards apply to cross-border flows, which the scenario does not raise.
  2. Carrying out a data protection impact assessment before the high-risk profiling processing begins ✓
    Correct: systematic, significant profiling likely to be high risk triggers a DPIA before processing.
  3. Notifying the supervisory authority of a personal data breach within seventy-two hours of awareness
    Almost right in flavor, but breach notification applies after an incident, not before a planned deployment.
  4. Appointing a data protection officer to oversee the organization's compliance with data protection law
    May be advisable, but a DPO appointment is a structural duty, not the assessment this processing triggers.
The trap
Selecting breach notification or a DPO appointment instead of the pre-processing DPIA that high-risk profiling triggers.

How to remember it

Large-scale, significant automated profiling likely to be high risk requires a DPIA before the processing starts.

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