Question: Are data protection impact assessments (DPIAs) or privacy risk assessments performed where applicable?
Objective — Why This Matters
DPIAs identify and mitigate privacy risks before they harm individuals or breach law. For MSMEs, simple DPIAs prevent reputational and financial damage while demonstrating proactive compliance under the DPDP Act.
Maturity Levels (0–5)
0 — Unaware
No DPIA activity; privacy risk unexamined.
No DPIA activity; privacy risk unexamined.
1 — Ad Hoc
DPIAs done only after issues arise.
DPIAs done only after issues arise.
2 — Defined
DPIA template and triggers documented (e.g., new system, vendor, large-scale processing).
DPIA template and triggers documented (e.g., new system, vendor, large-scale processing).
3 — Managed
DPIAs performed for all high-risk changes with recorded sign-offs.
DPIAs performed for all high-risk changes with recorded sign-offs.
4 — Integrated
DPIAs tied to risk register and change-approval workflow.
DPIAs tied to risk register and change-approval workflow.
5 — Optimized
Automated assessments with lessons-learned feedback loop and metrics.
Automated assessments with lessons-learned feedback loop and metrics.
How to Level Up
| From → To | Actions |
|---|---|
| 0 → 1 | Use the free MeitY DPIA template or NIRMATA sample checklist. |
| 1 → 2 | Define triggers (new processing / vendor / tech / sensitive data). |
| 2 → 3 | Train staff; require DPIA before go-live approvals. |
| 3 → 4 | Link residual privacy risks to enterprise register. |
| 4 → 5 | Automate reminders and analyze recurring mitigations for control improvement. |
People / Process / Technology Enablers
- People: Privacy Lead / DPO, Process Owners.
- Process: DPIA policy, workflow, sign-off matrix.
- Technology: Form templates, tracker, document repository.
Evidence Required
- DPIA register with status and approval date.
- Three sample DPIAs with mitigation records.
- Training materials or communication emails.
Metrics / KPIs
- Number of DPIAs completed per quarter.
- Avg days from trigger to approval.
- % high-risk findings closed on time.
Low-Cost / Open-Source Options (MSME)
| Purpose | Tool | Notes |
|---|---|---|
| Forms & Workflow | Google Forms + Sheets | Lightweight DPIA tracker. |
| Repository | GitHub / Drive | Version control for completed DPIAs. |
| Metrics | Metabase | Visualize trends over time. |
Common Pitfalls
- Treating DPIA as checkbox exercise.
- Missing privacy by design integration.
- No follow-up on mitigation actions.
Compliance Mapping
| Standard | Clauses / Notes |
|---|---|
| DPDP Act 2023 | Sec 10(3) – DPIA requirement. |
| ISO/IEC 27701 | §7.2.8 Privacy risk assessment. |
| NIST CSF 2.0 | ID.RA-5 (privacy impact). |
| NIRMATA Scoring | RC-Q06 Level ≥ 3 requires documented DPIAs + review records. |