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GDPR-ADVANCED5 MIN READ

DPIA Triage Decision Walk

Use a converging DPIA triage path to decide whether to proceed, narrow scope, or escalate residual risk.

High-risk feature The proposed attrition predictor combines employee notes, absence patterns, ratings, and survey text for 4,200 employees. Employees are a vulnerable context because power imbalance changes how risk is experienced. DPIA triage Signal -> Narrow -> Own A DPIA decision walk should identify risk signals, test proportional alternatives, and assign residual-risk ownership before processing starts. Shortcut Approve because HR already has the data. The design becomes more proportionate before launch. Do not ask whether the dataset exists. Ask whether the processing is necessary and whether a lower-risk design can serve the purpose. 01 Signal 02 Narrow 03 Own Spot…

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