Complete and document a GDPR Article 35 DPIA first: Which missing control is required before processing when
Likely high-risk processing requires a GDPR DPIA before processing, covering necessity, proportionality, risks, and safeguards.
The question
Under the GDPR in the European Union, a media company plans large-scale voice analysis to identify contributors across productions. The processing may significantly affect individuals, and ordinary safeguards are already designed. Which missing control is required before processing when the operation is likely to create high risk?
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- Adopt and publish a media-wide AI policy on responsible innovation.A general policy can guide governance but does not assess this processing's necessity, proportionality, risks, and safeguards.
- Encrypt stored and transmitted voice files.Encryption is an important safeguard, but it does not replace the required assessment when processing is likely to create high risk.
- Obtain consent from every contributor before analysis begins.Consent may be a lawful basis in suitable circumstances, but it does not substitute for a required high-risk DPIA.
- Complete and document a GDPR Article 35 DPIA first. ✓A GDPR Article 35 DPIA must assess necessity, proportionality, risks, and safeguards before likely high-risk processing begins.
The trap
When likely high risk is stated, select the processing-specific assessment required before processing. How to remember it
Likely high-risk processing requires a GDPR DPIA before processing, covering necessity, proportionality, risks, and safeguards.
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