What this control covers
Establish and maintain a DPIA programme covering: (i) DPIA template aligned with DPDPA and Rule 12; (ii) DPIA trigger criteria (mandatory for SDFs; recommended for high-risk processing); (iii) DPIA risk mitigation tracking; (iv) periodic DPIA review (at least annually for SDFs); (v) DPIA register with status of each assessment. Objective: Identify and mitigate risks to data principals' rights arising from processing activities before they materialise, and demonstrate proactive risk management to regulators.
Why it matters
Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.
How to implement
AWS
Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.
Azure
Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.
GCP
Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.
Google Workspace
Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
policy_document— A signed, version-controlled policy stating leadership intent and the named owner.
Signed policies, procedures, and registers document the safeguard. Focus: Data Protection Impact Assessment Programme.
Quick checklist
- Establish And Maintain — Data Protection Impact Assessment Programme
- Maintain — Data Protection Impact Assessment Programme
- Review — Data Protection Impact Assessment Programme
Related articles on this site
- GDPR Article 35: Data Protection Impact Assessment
- Data Privacy Regulations
- Acquisition Risk Management
- NIST 800-171 3.4.1 Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.