Artifact GuideUKDPIAs

UK GDPR Data Protection Impact Assessments

A controller must complete a DPIA before processing that is likely to result in a high risk to people's rights and freedoms.

Screen early, assess necessity and proportionality, reduce the risks, and consult the ICO before processing if high residual risk remains.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

A data protection impact assessment () is the documented process for describing proposed processing, testing necessity and proportionality, assessing risks to people, and selecting safeguards. The trigger is likely , not certainty that harm will occur. Start before design choices are fixed and before personal-data processing begins.

Search this module

Find a question or answer quickly

3 of 3 questions
Question 1

When is a DPIA required?

Article 35 states that a is in particular required for systematic and extensive automated evaluation on which legal or similarly significant decisions are based; large-scale processing of special-category or criminal-conviction and offence data; and systematic monitoring of a publicly accessible area on a large scale.

Also check the ICO's Article 35(4) list and high-risk indicators. Relevant indicators include evaluation or scoring, significant automated decisions, systematic monitoring, sensitive or highly personal data, large scale, combining datasets, vulnerable people, innovative technology, and preventing access to a right, service, or contract. Two indicators often point to a , but that is not a strict threshold; one may be enough.

  • Screen every new or materially changed processing activity before launch.
  • Assess nature, scope, context, purposes, people affected, data, technology, scale, duration, and likely harm.
  • Document a decision not to conduct a when high-risk indicators exist but the controller concludes likely is absent.
  • Use one for similar operations only when their risks and controls are genuinely similar.
Citations
Question 2

What must the DPIA contain?

At minimum, describe the processing and purposes, including any legitimate interest; assess necessity and proportionality; assess risks to people's rights and freedoms; and describe measures that address those risks, including safeguards, security, and mechanisms demonstrating compliance.

The controller remains responsible for the . Seek the DPO's advice where a DPO is designated, obtain processor and technical input, and consult affected people or their representatives where appropriate unless doing so would be disproportionate or prejudice commercial or public interests.

  • Map data sources, people, fields, inferences, systems, recipients, transfers, retention, deletion, and decision points.
  • Record lawful bases, Article 9 or 10 conditions, fairness, transparency, minimisation, accuracy, rights, security, and processor controls.
  • Describe each potential harm, who may experience it, likelihood, severity, existing controls, further action, owner, deadline, and residual risk.
  • Record DPO advice, stakeholder input, disagreements, approvals, and the decision to proceed, change, pause, or stop.
Citations
ICO - How do we do a DPIA?

ICO process for describing processing, consulting, assessing necessity and risk, identifying measures, sign-off, and integration into project plans.

Question 3

When must we consult the ICO or review the DPIA?

If the completed shows that processing would result in in the absence of measures and the controller cannot reduce that risk, Article 36 requires with the ICO before processing. Do not accept or sign off unresolved high residual risk as a business choice and launch anyway.

Review the when the risk represented by the processing changes. Triggers include new purposes, data, recipients, models, profiling, decisions, vulnerable groups, transfers, security architecture, incidents, complaints, or evidence that a control is ineffective.

Citations
Primary sources

References and citations

legislation.gov.uk
Referenced sections
  • Binding Articles 35 and 36 for DPIAs and prior consultation.
ico.org.uk
Referenced sections
  • Explains the prior-consultation threshold, submission information, and the need not to proceed while unresolved high risk remains.
ico.org.uk
Referenced sections
  • ICO process for describing processing, consulting, assessing necessity and risk, identifying measures, sign-off, and integration into project plans.
ico.org.uk
Referenced sections
  • Explains likely high risk, the Article 35 cases, the ICO list, nine indicators, and documented screening decisions.
Related guides

Explore more topics

How do you choose a lawful basis under the UK GDPR?
Choose and document the UK GDPR lawful basis that fits each processing purpose, including recognised legitimate interest, in force since 5 February 2026.
UK Children's Code: Scope and 15 Standards
Decide whether an online service is likely to be accessed by UK children and apply the ICO Children's Code standards to product design and personal-data use.
UK GDPR 72-hour Breach Reporting Guide
Decide whether a UK personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report must contain, and when individuals must be told.
UK GDPR 72-Hour Breach Reporting: Decision Guide
Decide whether a personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report needs, and when affected people must be told.
UK GDPR Adequacy Guide
Use UK transfer approval regulations by checking the destination, recipient, data, sector, effective status, scope limits, and review evidence.
UK GDPR Adequacy: When Can You Rely on It?
Check whether current UK adequacy regulations cover a restricted transfer, including partial coverage for Canada, Japan, and the US UK Extension.
UK GDPR AI and Automated Decisions Guide
Current UK GDPR rules for significant solely automated decisions, meaningful human involvement, Article 22B restrictions, and Article 22C safeguards.
UK GDPR AI and Automated Decisions: Articles 22A-22D
Apply the current UK rules for significant solely automated decisions, special-category restrictions, meaningful human involvement, and Article 22C safeguards.
UK GDPR Applicability Test Guide
Apply the UK GDPR material and territorial scope tests to one processing activity, including exclusions, non-UK organisations, roles, and evidence.
UK GDPR Article 30 Records Guide
Build UK GDPR Article 30 records for controller and processor activities, apply the narrow under-250 exception, and keep the records current and available to the ICO.
UK GDPR Article 30 Records: What to Document
See which controllers and processors need records of processing activities, what each record must contain, and how the under-250-employee exemption works.
UK GDPR Breach Notification Guide
Decide whether a personal data breach must be reported to the ICO or communicated to individuals, with deadlines, exceptions, content, and evidence.
UK GDPR Breach Workflow Guide
Run a UK GDPR personal data breach workflow from containment and awareness through risk assessment, ICO reporting, individual notice, and the breach record.
UK GDPR Children and Age Appropriate Design Guide
Apply UK GDPR children's protections and the Age Appropriate Design Code to online services likely to be accessed by children.
UK GDPR Children's Code Guide
A practical guide to Children's Code scope, its 15 standards, age 13 consent, evidence, exceptions, and product implementation.
UK GDPR Compliance Checklist
A verifiable UK GDPR checklist for scope, lawful processing, transparency, rights, governance, security, breaches, DPIAs, children, and transfers.
UK GDPR Compliance FAQ: Duties, Rights, and Decisions
Answer common UK GDPR questions on scope, lawful basis, records, DPIAs, DPOs, rights, breaches, children, automated decisions, and international transfers.
UK GDPR Compliance Guide
Build a UK GDPR compliance programme around processing records, lawful decisions, rights operations, security, incidents, DPIAs, suppliers, and transfers.
UK GDPR Controller and Processor Status Guide
Decide whether each party is a controller, joint controller, or processor under the UK GDPR, then record the role-specific duties, contract terms, and evidence.
UK GDPR Controller or Processor: How to Decide
Decide whether each party is a controller, joint controller, processor, or sub-processor, then record the contracts, responsibilities, and evidence the role requires.
UK GDPR Data Subject Rights Guide
Operate UK GDPR access, rectification, erasure, restriction, portability, objection, and automated-decision rights under the amended Article 12 timing rules.
UK GDPR Deadlines and Compliance Calendar Guide
Track UK GDPR deadlines for rights requests, privacy information, breach notification, DPIAs, and ICO prior consultation, with triggers and exceptions.
UK GDPR DPIA Workflow Guide
Screen UK GDPR processing for likely high risk, complete the required DPIA analysis before processing, reduce risk, and consult the ICO when high residual risk remains.
UK GDPR DPIAs and DPOs Guide
Decide when the UK GDPR requires a DPIA or DPO, what each must cover, when to consult the ICO, and what evidence to retain.
UK GDPR DPO: When Appointment Is Mandatory
Apply the three UK GDPR DPO triggers and document expertise, independence, reporting line, resources, tasks, contacts, and conflict controls.
UK GDPR DSAR Workflow Guide
Run a UK subject-access workflow using the current Article 12A clock, reasonable identity and clarification steps, proportionate searches, exemptions, redactions, and response evidence.
UK GDPR IDTA Addendum and Transfer Risk Assessment Guide
Choose the UK IDTA or Addendum, complete the current Article 46 data protection test, add needed measures, and maintain evidence for restricted transfers.
UK GDPR Lawful Bases Guide
Choose among the six familiar Article 6 bases and the UK's recognised legitimate interests basis, then document any Article 9 or 10 condition.
UK GDPR PECR Cookies Guide
UK GDPR and PECR cookie guidance with practical consent, exemption, evidence, and cited implementation decisions.
UK GDPR Penalties and Fines: Maximums and ICO Factors
Understand the UK GDPR £8.7 million or 2% and £17.5 million or 4% fine ceilings, which infringements fall into each band, and how the ICO sets a fine.
UK GDPR Requirements Guide
Map UK GDPR requirements by processing activity, role, lawful basis, data type, risk, rights, suppliers, automated decisions, and transfers.
UK GDPR Transfer Workflow Guide
Apply the UK GDPR restricted-transfer sequence: map the transfer, check Article 45A approval, choose an Article 46 safeguard and assessment, or justify a specific Article 49 derogation.
UK GDPR Transfers, IDTA, and UK Addendum Guide
Decide whether a UK restricted transfer exists, whether adequacy applies, how to use the IDTA or UK Addendum, and how to document the data protection test.
UK GDPR vs Data Protection Act 2018: How They Work Together
See when to use the UK GDPR, when the Data Protection Act 2018 adds a condition or exemption, and which regime covers law enforcement or intelligence processing.
UK GDPR vs EU GDPR: Scope, Regulators and Transfers
Determine whether UK GDPR, EU GDPR, or both apply, then separate representatives, regulators, transfer routes, national law, and post-Brexit UK amendments.
UK IDTA vs EU SCCs: Which Transfer Contract to Use
Choose between the UK IDTA and EU SCCs with the UK Addendum, complete the right documents, and record the separate UK and EU transfer assessments.
UK IDTA, Addendum, and Transfer Risk Assessment Guide
Decide when to use the UK IDTA or Addendum, complete the Article 46 data protection test, add supplementary measures, and keep the transfer under review.
UK vs EU GDPR Differences After the 2025 UK Reforms
Compare current UK and EU rules for recognised legitimate interests, rights requests, access searches, automated decisions, and international transfers.
UK vs EU GDPR Operations: Regulators, Breaches and Transfers
Configure separate UK and EU privacy operations for representatives, regulator contacts, rights requests, breach reporting, transfer tools, and evidence.
When do PECR cookie rules require consent?
Apply the current UK PECR rules to cookies and similar technologies, including consent, five exceptions, UK GDPR overlap, and evidence.