Complete a GDPR DPIA before processing: What must happen before | AIGP
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Complete a GDPR DPIA before processing: What must happen before processing begins?

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

A documented likely-high-risk finding requires a GDPR DPIA before processing begins.

The question

Under the GDPR in the EEA, a university research-administration unit will systematically monitor identifiable student records at large scale, including health-related absences. Its documented threshold review concludes that the processing is likely to result in high risk, and no GDPR DPIA has been completed. What must happen before processing begins?

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  1. Complete only a broad AI impact assessment covering the project.
    A broader assessment may supplement governance, but it does not substitute for the GDPR DPIA required by the stated threshold finding.
  2. Rely on the research purpose and security policy.
    Those materials do not assess this processing’s necessity, proportionality, risks, or safeguards as required by a DPIA.
  3. Complete a GDPR DPIA before processing. ✓
    Because the documented review finds likely high risk, GDPR Article 35 requires a DPIA before processing begins.
  4. Run a pseudonymized pilot first.
    A pilot may reduce exposure, but it does not replace the required DPIA when the processing is likely to result in high risk.
The trap
When the facts expressly establish likely high risk, select the Article 35 DPIA rather than a substitute assessment.

How to remember it

A documented likely-high-risk finding requires a GDPR DPIA before processing begins.

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