Call the DPIA Before the Build Hardens
Decide when a DPIA should be triggered before product and data-architecture choices become expensive to change.
A DPIA is an early-warning system for design risk. It should happen when the team can still change the data, model, audience, or default behavior. Screen for risk signals High-risk processing is not limited to obviously sensitive projects. Look for systematic scoring, monitoring, large-scale profiling, vulnerable groups, special-category data, invisible processing, or decisions with meaningful effects. Treat it like risk management Borrow the ISO 31000 logic: set the context, identify risk sources, assess impact and likelihood, choose treatments, and record residual risk. A DPIA is stronger when it shows the chain from risk to control. Use the result to change…
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