Privacy Impact Assessments (PIA)
Maturity Level
Level 0: Non-Existent
The practice is not implemented or acknowledged.
PIAs are never conducted.Example Strategies
- Identify individuals within the entity who have familiarity of knowledge of the IT systems and data processing who can begin an initial inventorying and prioritization process for where a PIA should be conducted until permanent individuals to formally address the issue are established.
Level 1: Ad Hoc
Practice may occur but is undocumented (no policies or procedures), application is reactive and not standardized.
PIAs might be informally considered for very high-risk projects, but there's no formal process or documentation.Example Strategies
- Formalize the PIA process with a standardized template and guidance.
- Develop a clear PIA form and an internal policy outlining when a PIA is required (e.g., for all new systems or significant changes involving personal data) and who is responsible for completing it.
Level 2: Defined
Practice is implemented and documented, but documentation may not cover all relevant aspects, and application may be informal and inconsistent.
A PIA template exists, and some PIAs are conducted, but the process may be inconsistent, lacking rigor or follow-up on identified risks.Example Strategies
- Enforce mandatory PIAs for all relevant projects and ensure consistent review and follow-up.
- Integrate PIA completion as a mandatory gate in the entity's project management lifecycle, with reviews by legal and privacy officers before system deployment.
Level 3: Consistently Implemented
Practice is documented to cover all relevant aspects, application is formal and consistent.
PIAs are formally and consistently conducted for all new or significantly modified systems and initiatives involving personal data, with documented risk assessments and mitigation plans.Example Strategies
- Track PIA outcomes, identified risks, and mitigation effectiveness.
- Implement a system (even a simple spreadsheet initially) to log all PIAs, track identified privacy risks, monitor the implementation status of mitigation plans, and periodically review their effectiveness
Level 4: Managed
Practice is actively managed with metrics that are regularly reviewed to assess efficacy and facilitate improvement.
The entity tracks the number of PIAs conducted, the types of risks identified, and the effectiveness of implemented mitigation strategies. Findings inform improvements to the PIA process itself.Example Strategies
- Proactively integrate privacy-by-design principles and automate PIA workflows.
- Implement a privacy management software solution that automates PIA workflows, provides a centralized repository for assessments, and integrates with data inventories to identify high-risk areas for proactive assessment.
Level 5: Optimized
Practice is fully embedded in the entity with recognition and understanding across the workforce through active training and awareness campaigns, and inclusion in operations and strategy.
PIAs are integrated into the project lifecycle from the very beginning (privacy-by-design), serving as a core component of risk management and continuous privacy improvement, with a dedicated team or tools to support the process.