WorkflowData Privacy & AI Governance

Privacy Impact Assessment

DPIA software that drafts from the project's own documents and shows every risk move before you sign

Every new project assessed before launch, with each answer traced to its source.

See one case, screen by screen ↓
demo41of 48DPIA questions pre-answered from the brief, diagram and vendor contract, each with its passage
demo3 → 0high riskson the sample DPIA once the privacy officer accepted the controls — 1 medium and 7 low remain
target100%of high-risk launches with a signed DPIA before go-live
target8daysfrom start to sign-off, against the demo company's 34-day median in 2025
In short

What is Privacy Impact Assessment?

DPIA software that drafts and scores privacy impact assessments and DPIAs for new projects and vendors. Seven agents screen each project, pre-answer the questionnaire from its own brief, diagram and contract with the passage behind every answer, challenge every data field and score each risk before and after its controls. The privacy officer accepts every control and the residual risk, and the DPO advises and decides any prior consultation.

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Updated

The problem

Why a DPIA is finished the week before go-live, or after it

Before high-risk processing starts, GDPR Article 35 requires a data protection impact assessment: a systematic description of the processing, an assessment of necessity and proportionality, the risks to people and the measures that address them. California's risk-assessment regulations and the Colorado and Virginia laws now ask for the same kind of assessment. In most companies it is a 40 to 80 question form sent to a project owner who cannot answer it, forwarded to the architect and the vendor, and returned partial and without evidence. The privacy officer then rewrites the answers into a description of processing and scores risks in a spreadsheet, from memory or an old DPIA.

The answers were in the project's own brief, architecture diagram and vendor contract all along; nobody had time to read them side by side. So necessity is rarely challenged — "is each field needed?" is answered "yes" — controls are agreed in meetings but never evidenced, nobody records who accepted which residual risk, and the DPIA is filed and forgotten when the vendor adds a sub-processor or the design adds GPS. A DPIA that arrives after launch changes nothing and still costs weeks.

typical€10Mor 2%of worldwide annual turnover, whichever is higher: the maximum fine for breaching Articles 35 and 36
typical8 + 6weeksthe most a supervisory authority may take to advise on a prior consultation when high risk remains
typical2 of 9criteriain most cases make a DPIA necessary under the EDPB guidelines
Where a DPIA's calendar days goestimated
By hand34 days
With the solution8 days
  • Screening and deciding whether a full DPIA is needed3 → 0.5 d
  • Getting the questionnaire answered by the owner, architect and vendor14 → 2 d
  • Writing the description of processing3 → 0.5 d
  • Scoring the risks and agreeing controls6 → 2 d
  • Necessity, and evidence for each control4 → 1 d
  • DPO advice, works council and sign-off4 → 2 d

Estimated split for one full DPIA, from the demo company's 34-day median in 2025 to the 8 days of the sample case.

How it works

How one project is assessed

Seven agents screen, draft, challenge, score and re-check; the privacy officer signs and the DPO advises.

What comes in
Project inProject portal, procurement, documents · brief, diagram, contract
Agents at work
Screening agentthreshold test
Then
Intake agent41 of 48, cited
Necessity agentkeep, limit, drop
Then
Risk agentbefore and after
Control checkerindependent
Then
Consultation agentDPO and works council
Change watcher
A person decides
Privacy officer and DPOaccept, advise, sign
What comes out
Every answer cited
Risks moved, not just listed
Signed DPIA
One case, step by step

One DPIA, from submitted project to signed

Kestrel & Vane Distribution wants a driver-facing fatigue camera from Ocellus Telematics in 1,860 trucks driven by 2,340 people in Germany, the Netherlands, Poland and Spain — pilot Mon 2 Nov, go-live Wed 2 Dec 2026. Here is DPIA-2026-118, screen by screen, in the working solution.

  1. 01Wed 14 Oct, afternoon

    Six things need her, and the agents say which first

    Sofia Brandt · Privacy Officer

    Sofia's home screen opens with a summary: the agents screened 3 new projects and re-checked 9 assessments since yesterday, and 6 things need her, led by DriveAlert. What the agents found sits in plain sentences with its sources: the risk agent and necessity agent propose dropping DriveAlert's face login, the control checker disputes a blurring control, and the screening agent flags palm-scan payments in the canteens.

    “They answer from the assessments and documents, with sources, and act only when you say so.” — the Ask the agents panel

  2. 02Tue 6 Oct, 08:31

    A minute after Tomas submits it: full DPIA

    Screening agent

    Tomas Herrera submits DriveAlert through the project portal at 08:30. The screening agent runs the threshold test: 5 of the 9 criteria — evaluation or scoring, systematic monitoring, sensitive data, vulnerable people (employees) and innovative technology — plus biometrics and tracking on the authority's list. Each criterion it ticks carries its source. Laws that apply: EU GDPR, and works council co-determination in Germany. Sofia confirms at 10:14 and DPIA-2026-118 opens.

    The screening agent recommends; it never decides “no DPIA” on its own, and every override is recorded with a reason.

  3. 03Tue 6 Oct, 10:31

    41 of 48 questions answered from the documents

    Intake agent

    The intake agent reads the project brief v1.3, the architecture diagram v0.9 and the Ocellus master services agreement and DPA draft — 47 pages — and pre-answers 41 of the 48 questions in six sections, each with its source and a confidence score. What the documents do not say, it asks: 5 questions to Tomas, 2 to Kwame Asante in information security. It also writes the processing description: 8 operations, from recording the cab to recording the road ahead.

    The intake agent never answers without a source; it leaves a question open rather than guess.

  4. 04One click

    Every answer opens the passage behind it

    Tomas Herrera · project owner

    Q14 asks whether special category data is processed. The answer — yes, a face template stored to identify each driver — links to the contract, §4.2: the processor creates a facial template of each driver and stores it in its cloud for the term of the agreement. The passage shows who read it: the intake agent on Tue 6 Oct, and the control checker again on Wed 7 Oct. Tomas only confirms or corrects.

    “Tell me what you need from me and I'll confirm it.” — Tomas Herrera

  5. 05The risk map

    Each risk drawn twice, before and after

    Risk agent and necessity agent

    The risk agent found 8 risks: 3 high, 5 medium. On the 4 × 4 map each one is a ring where it starts and a dot where its controls take it, joined by an arrow; an unaccepted move stays dashed. Pick P2, “Log the driver in by face”, and only R1 stays lit: biometric identification, 3 × 4 = 12, high. In the conversation beside the map the risk agent proposes two controls from the company's own library, and the necessity agent asks why face login is needed at all: drivers already badge in at every shift.

    “I propose two controls from our library: CL-07 edge-only processing with badge login, and CL-03 deletion of clips after 72 hours. Then R1 is 2 × 3 = 6, medium.” — Risk agent

  6. 06She asks back

    “What if we keep face login?”

    Sofia Brandt · Privacy Officer

    Sofia asks in plain words before she decides. The risk agent answers with its sources: R1 stays at 3 × 4 = 12, high, even with 72-hour deletion, because the template itself is the risk. A privacy officer cannot accept a high residual risk, so Annelies de Groot would have to decide on prior consultation — and the authority can take 8 weeks, plus 6, past the pilot on 2 Nov.

  7. 07Accepted · A1

    She accepts, and the arrow moves from high to medium

    Sofia Brandt · Privacy Officer

    Sofia accepts both controls with reason code A1, “Controls adequate and owned”. The dashed arrow turns solid: R1 moves to 2 × 3 = 6, medium. The control checker had already checked both controls against the contract on its own: edge-only mode exists, and clip retention can be set from 24 hours to 90 days. The risk agent reports the new picture — 0 high, 1 medium and 7 low — and says what is next: settle R5, then sign.

    What remains of R1, in the risk agent's words: the camera still reads drivers' faces to infer fatigue, a health-adjacent state.

  8. 08A disagreement

    A second agent disagrees out loud

    Control checker

    R5's control says faces and number plates in the road camera's clips are blurred before upload. The control checker, which never sees the risk agent's reasoning, read the contract itself: Annex 2 §2.4 says blurring happens only when a clip is downloaded or exported. It scores R5 at 2 × 1, not 1 × 1. Sofia keeps the checker's 2 × 1 until Ocellus confirms blurring before upload, and that confirmation becomes a condition of the sign-off.

    The control checker can block sign-off; it cannot accept a risk.

  9. 09Necessity

    Every data field challenged against the purpose

    Necessity agent

    The purpose is to reduce fatigue-related collisions by alerting drivers and dispatchers. Against it the necessity agent challenged 12 fields: drop 4 — the face template, continuous cab video, cab audio and the heart-rate wristband — limit 4 and keep 4, each with its reason and source. Accepting R1 decided two of them; 10 of 12 are decided, and the project owner may still contest GPS every second or the weekly score per driver with a reason.

  10. 10Wed 14 Oct, 14:05 · signed

    Residual risk medium, accepted with conditions

    Sofia Brandt · Privacy Officer

    Annelies recorded her Article 35(2) advice on Tue 13 Oct, and the consultation agent's plain-words summary went to Petra Lindholm, the works council chair. Sofia accepts the necessity agent's two remaining proposals — limit GPS to the event location, and the weekly score to trends — and with all five checks done she accepts the residual risk with reason code RA2, “Accepted with conditions”: Kwame's transfer impact assessment and penetration test, the works-council summary, Ocellus's written confirmation on blurring, and a review in 12 months or at once on any vendor or design change. She types her name to sign — eight days after the project arrived.

    “Recorded with your name, the time and the evidence on the audit trail.”

Who it’s for

Built for everyone who signs off a DPIA.

The same DPIA, seen by four of the people who carry it — what an assessment looked like, and what it looks like now.

SB
Sofia BrandtPrivacy Officer, Group Privacy Office · 9 DPIAs in flight, 5 screenings a week
Privacy Officer
Before
Chases a 48-question form through the project owner, the architect and the vendor, then scores risks in a spreadsheet and hopes it is signed before go-live.
Now
Opens one map where every risk is drawn before and after, asks the agents why, accepts each control with a reason code and signs — with the passage behind every answer.
TH
Tomas HerreraHead of Fleet Safety, Kestrel & Vane Distribution · project owner
Project owner
Before
Gets a questionnaire about Article 35 he cannot answer, and forwards it to the architect and the vendor.
Now
Confirms answers already drafted from his own brief, diagram and contract, and answers only the 5 questions the documents did not.
Ad
Annelies de GrootGroup Data Protection Officer · advises on every DPIA, decides prior consultations
Data Protection Officer
Before
Hears that high risk remains the week before launch, with no pack ready for the authority.
Now
Records her advice in the DPIA itself, and decides any prior consultation with the Article 36(3) pack already drafted and checked.
KA
Kwame AsanteInformation Security Analyst · reviews vendor security evidence
Information security
Before
Is asked to vouch for encryption and access controls whose evidence lives in email.
Now
Confirms security controls against the vendor's SOC 2 report, while a second agent re-checks every control against the contract.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents screen, draft, challenge, score and re-check; the privacy officer signs and the DPO advises.

Screening agent

Runs the threshold test on every new project or vendor within minutes: the nine EDPB criteria, the authority's list and the US state triggers, with the reason for each criterion and the laws that apply.

  • Never decides “no DPIA” alone
  • Records its reasons; the privacy officer confirms or overrides
Intake agent

Reads the project brief, the architecture diagram and the vendor contract together, pre-answers the questionnaire with the passage behind each answer, and writes the description of processing.

  • Never answers without a source
  • Leaves a question open and asks the owner rather than guess
Necessity agent

Challenges every data field against the stated purpose and proposes keep, limit or drop, with its reason and source.

  • Proposes only; the project owner may contest
  • The privacy officer decides
Risk agent

Finds the risks in each processing operation, scores likelihood × severity with its reasons, and proposes controls from the company's own control library.

  • Never accepts a risk or a control
  • Proposes only controls already in the library
Control checker

Re-checks each control against the evidence — contract clauses, the vendor's security report — and re-scores on its own, saying so when it disagrees.

  • No access to the risk agent's reasoning
  • Can block sign-off; cannot accept
Consultation agent

Drafts the works-council summary in plain words, the DPO advice record and the prior-consultation pack, checked against Article 36(3)(a)–(f).

  • Sends nothing without a person
Change watcher

Watches vendor notices, new design documents, scope changes and review dates for every approved DPIA, and proposes reopening only the answers and risks a change touches.

  • Reopens, never closes
  • Names the answers and risks a change affects
Privacy officer, DPO, project owner

Reason codes, e-signatures. The agents propose; a named person decides.

Ask in plain words

Ask the agents, in plain words

Ask about any risk, answer or data field — or tell the agents what to draft. Every answer points to the passage it came from, and nothing changes until you accept it.

Why is R1 high and not medium?

Two things push it up. Severity 4: a face template cannot be changed if it leaks, and it identifies the person. Likelihood 3: it is stored centrally for the whole contract, for 2,340 drivers. Our matrix calls 9 and above high.

What if we keep face login?

Then R1 stays at 3 × 4 = 12, high, even with 72-hour deletion: the template itself is the risk. A high residual risk cannot be accepted by a privacy officer; Annelies would have to decide on prior consultation, and the authority can take 8 weeks, plus 6, past the pilot on 2 Nov.

What is left before sign-off?

Your decision on R1, and which score stands for R5. Then sign. Annelies's advice is recorded. Three conditions will carry into the sign-off: Kwame's transfer impact assessment and penetration test, and the works-council summary before the pilot.

Draft the works council summary

Done: one page in plain words for Petra Lindholm — what the camera records, what it will never be used for, how long clips are kept, and how a driver contests an alert. It is on the sign-off page; nothing is sent until you say so.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayWhat needs the privacy officer today: what the agents found overnight, with sources, a box to ask them, and what is coming due.
ScreeningEvery new project and vendor screened against the nine criteria and the authority's list, with the laws that apply and the decision on record.
The questionnaire48 questions in six sections, each answer with its source and confidence; filter to what came from the documents, the owner's answers or what is still open.
Where an answer came fromThe contract clause behind an answer, highlighted, with the risks it feeds and which agents read it.
Risks, before and afterThe processing description, the likelihood-by-severity map with each risk drawn before and after its controls, and the conversation with the agents.
Asking the agentsA question asked in plain words, answered with its sources, before anything is accepted.
A control acceptedThe arrow moves from high to medium once the privacy officer accepts; the risk agent reports what is left.
The second checkThe control checker's disagreement with the clause it rests on, and the choice of which score stands.
NecessityEvery data field challenged against the purpose — drop, limit or keep — with the reason, the source and the owner's right to contest.
Accept and signThe reason code, the conditions that carry into the approval, the typed signature and the DPO's advice read.
Prior consultationWhy high risk remains, the pack checked against Article 36(3), the letter to the authority, its clock, and the DPO's decision.
What changedA vendor's new sub-processor caught by the change watcher, before and now, the answers and risk it touches, and reopen or dismiss.
Audit trailEvery action by people and agents in order, each entry chained to the one before, and the evidence pack to export.
Governance

Built for accountability: cited, decided, on the record.

Every answer and score cites its passageEach answer, risk score, control and agent statement links to the page or clause it came from — the brief, the diagram, the contract, the SOC 2 report or the law — and a click opens it.
People accept every control and the residual riskThe project owner confirms answers; the privacy officer accepts each control and the residual risk with a reason code and a typed e-signature; information security confirms security controls with evidence.
Residual high always goes to the DPOA privacy officer may accept residual risk up to medium. A high residual risk is never accepted quietly: the DPO decides to consult the authority, send the project back for redesign, or stop it.
An independent second checkThe control checker re-checks every control against the contract and the vendor's evidence without seeing the risk agent's reasoning. Its disagreement is shown, it can block sign-off, and a person decides which score stands.
No one signs what they preparedSign-off stays closed while anything is open, the person who prepared a DPIA cannot sign it, and no agent signs, accepts a risk, sends anything outside the company or closes a reopened DPIA.
A chained audit trailEvery action by people and agents is recorded in order, each entry chained to the one before it. The evidence pack exports the DPIA, every answer with its passage, the decisions and signatures, with a hash.
Configuration

Your privacy rules, not ours

What the agents may do, who decides and how risk is scored are settings. Changes are saved as a new version and take effect when the DPO approves them.

SettingDefaultChoose from
High risk from9 on the 4 × 4 matrix8 · 9 · 12
Residual high goes toThe DPO, for a prior-consultation decisionExisting DPIAs keep the matrix they were scored with
Privacy officer may accept residual riskUp to mediumRoles: privacy officer · DPO · project owner · information security · works council · auditor
When a full DPIA is neededTwo or more of the nine criteria, or any item on the authority's listSame processing as an approved DPIA: reuse it and record the reason
TemplatesGDPR DPIA (48 questions), UK GDPR DPIA, California risk assessment, Colorado and Virginia data protection assessmentAlso a light privacy review for vendor changes, and an AI impact assessment with the AI Act team
Control library14 controls, each with an owner and the evidence it needsThe risk agent proposes only from this library · add a control
ReviewEvery 12 months, and on any vendor, design or scope changeVendor sub-processor notice: affected DPIAs reopened the same day
Service levelsScreening in 2 business days; owner questions and DPO advice in 5Reminders at 2 and 5 days · go-live within 14 days and unsigned: escalate to the DPO and the business head
Connections

Works with the systems a project already lives in

Project portalnew projects, their briefs and screening requests
Procurement intakenew vendors, contracts and data processing agreements
Document librarybriefs, architecture diagrams, design documents
Record of processingactivities, purposes and retention
Vendor risk registersub-processor notices and security reports
Ticketing, email and chatowner questions, reminders, notifications and approvals
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of high-risk launches with a signed DPIA before go-live; a missed one can cost up to 2% of turnover
202563 of 74
With agentsevery one
target
4of 12
data fields dropped before launch in the hero case, every field challenged by the necessity agent
4 of 12
fields dropped
target
8days
from start to sign-off, with 41 of 48 answers drafted from the documents, from a 34-day median
Today34 days
With agents8 days

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (GDPR Art. 83(4)(a) — up to €10 million or 2% of worldwide annual turnover, whichever is higher; GDPR Art. 36(2) — the authority advises within eight weeks, extendable by six; WP29/EDPB guidelines WP248 rev.01 — two of the nine criteria in most cases mean a DPIA). The 34-day median is the demo company's 2025 baseline. People, companies, projects and vendors named on this page are fictional — characters and sample data in the working solution.

Questions

What privacy teams ask us.

What is Privacy Impact Assessment?

DPIA software that drafts and scores privacy impact assessments and DPIAs for new projects and vendors. Seven agents screen each project, pre-answer the questionnaire from its own brief, diagram and contract with the passage behind every answer, challenge every data field and score each risk before and after its controls. The privacy officer accepts every control and the residual risk, and the DPO advises and decides any prior consultation.

How does it decide whether a project needs a DPIA?

The screening agent tests every new project and vendor against the nine EDPB criteria, the authority's list and the US state triggers, and cites the reason for each. Two or more criteria, or any item on the authority's list, means a full DPIA. The privacy officer confirms or overrides with a reason code, so a “no DPIA” decision is documented too.

Can the AI answer the DPIA questionnaire instead of the project owner?

It drafts what the documents answer and the owner confirms. On the sample DPIA the intake agent answered 41 of 48 questions from the brief, diagram and vendor contract, each with its passage, and asked the owner and information security the 7 the documents did not cover. It never answers without a source, and high-confidence answers can be confirmed in one step.

Does it handle CPRA risk assessments and US state data protection assessments?

Yes. Templates cover the GDPR and UK GDPR DPIA, the California risk assessment and the Colorado and Virginia data protection assessment, and the screening agent names the laws that apply. In the sample, profiling US loyalty members triggers all three state assessments in one assessment.

What happens when high risk remains after mitigation?

A privacy officer cannot accept it; it goes to the DPO. The consultation agent drafts the prior-consultation pack and checks it against Article 36(3)(a)–(f), with the cover letter and the authority's clock of 8 weeks, plus 6. The DPO decides to consult the authority, send the project back for redesign, or stop it, with a reason code.

Does the DPIA stay up to date when the vendor or design changes?

The change watcher follows vendor notices, design documents, scope and review dates for every approved DPIA. When a vendor adds a sub-processor, it names the answers and risks the change touches and proposes reopening only those. The privacy officer reopens them or dismisses the change with a reason.

Do people stay in control of the assessment?

Yes. The agents propose, explain and cite; they never sign, accept a risk, send anything outside the company or close a reopened DPIA. The project owner confirms answers, the privacy officer accepts each control and the residual risk with a reason code and e-signature, an independent checker can block sign-off, and no one signs a DPIA they prepared.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your questionnaire templates, control library, scoring matrix and the systems your projects live in — and it goes live once every quality gate has passed. Setup ends with a test on one of your approved DPIAs: the agents re-draft it from its documents and you compare the answers. Nothing goes live until the test passes and the DPO approves.

See it on
your next project.

We'll run Privacy Impact Assessment on one of your own past DPIAs and the documents behind it.