Document purposes: Which evidence should resolve the approval uncertainty?
A contextual DPIA assessment must connect processing characteristics, rights risks, safeguards, and residual risk before approval.
The question
Under the GDPR, an insurer proposes an AI claims triage tool using health information and cross-border vendor hosting. The team has not shown whether processing is likely high risk or whether safeguards reduce residual risk. Which evidence should resolve the approval uncertainty?
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- Obtain the vendor’s general security certification and product brochure.These materials may describe security, but they do not assess processing necessity, proportionality, affected rights, or residual risk.
- Confirm encryption and pseudonymization protect all claims before deployment.Technical protections matter, but pseudonymization remains personal-data processing and cannot alone resolve the broader high-risk assessment.
- Obtain written approval from the insurer’s procurement and technology committees.Internal approvals may establish governance, but they do not demonstrate the GDPR’s contextual risk assessment or safeguard evaluation.
- Document purposes, data scale, affected rights, safeguards, and residual risk. ✓This evidence tests high-risk indicators and DPIA requirements, including necessity, proportionality, risks, safeguards, and remaining exposure.
The trap
For DPIA questions, look for evidence linking processing context, rights impacts, necessity, proportionality, safeguards, and residual risk. How to remember it
A contextual DPIA assessment must connect processing characteristics, rights risks, safeguards, and residual risk before approval.
How many of these would you get right?
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