← NDPA 2023 · Accountability

s.28 — Data privacy impact assessment

high dpiarisk-assessment

Requirement

Where processing is likely to result in a high risk to the rights and freedoms of a data subject, the data controller shall, before the processing, carry out a data privacy impact assessment (s.28). The GAID 2025 lists mandatory cases — including profiling, automated decisions, systematic monitoring, sensitive data and digital financial or health services (Art. 28).

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
dpiadata protection impact assessmentprivacy impact assessmentdata privacy impact assessment
Required element 2 — any one of
high riskbeforeprior toscreeningthreshold
Supporting terms — specificity signals
section 28mitigationconsultregistertemplatenew processingconsultation
Contradiction markers

Finding any of these outranks coverage — a policy that admits the gap is worse than silence.

no dpia process

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.35 Data protection impact assessment dpia risk-assessment
GDPR Art.36 Prior consultation with the supervisory authority dpia risk-assessment
CCPA/CPRA Regs (risk assessments) Risk assessments for significant-risk processing dpia risk-assessment
SOC 2 CC3.1 Objectives and risk identification risk-assessment
SOC 2 CC3.2 Risk analysis and response risk-assessment
SOC 2 CC3.3 Fraud risk risk-assessment
SOC 2 CC3.4 Assessment of significant change risk-assessment
ISO 27001 A.5.8 Information security in project management risk-assessment