You are a consulting Data Protection Officer (DPO) for a holiday resort You have been asked to conduct a Data Protection Impact Assessment (DPIA) for…

A Data Protection Impact Assessment (DPIA) is a mandatory internal process under the GDPR for high-risk processing. It requires a systematic description of the processing (A), the identification of measures to mitigate risks (C), and a formal sign-off and recording of outcomes for accountability (B). However, there is no legal requirement to publish the potential risks identified during this internal assessment in a public-facing information (privacy) notice. While transparency is key, the privacy notice's purpose is to inform individuals about the nature of the processing, their rights, and the legal basis, not to detail the internal risk management process. Publishing such risks could be counterproductive and is not mandated by GDPR Articles 13 or 14.

A. Describing the processing is a foundational requirement of a DPIA, as specified in Article 35(7)(a) of the GDPR, to understand the data flows and context.

B. Signing off and recording outcomes is essential for the principle of accountability, demonstrating that the DPIA was conducted, reviewed, and its conclusions formally accepted.

C. Identifying measures to mitigate risks is a core purpose of the DPIA, mandated by GDPR Article 35(7)(d), to reduce the potential harm to individuals.

1. General Data Protection Regulation (EU) 2016/679, Article 35(7): This article explicitly lists the minimum required components of a DPIA. It states the assessment shall contain at least: "(a) a systematic description of the envisaged processing operations...; (c) an assessment of the risks to the rights and freedoms of data subjects...; (d) the measures envisaged to address the risks...". This directly supports that A and C are requirements.

2. Information Commissioner's Office (UK), "Data protection impact assessments," Guide to the GDPR: In the section "How do we carry out a DPIA?", the ICO outlines the process, which includes the steps: "Step 6: Identify measures to reduce the risk" and "Step 7: Sign off and record outcomes." This guidance confirms that B and C are integral parts of the standard DPIA process.

3. Article 29 Data Protection Working Party, "Guidelines on Data Protection Impact Assessment (DPIA) and determining whether processing is 'likely to result in a high risk' for the purposes of Regulation 2016/679" (WP 248 rev.01), page 11: The guidelines state, "A DPIA is a process... It should be recorded in writing and should result in a concrete plan to manage the identified risks." This supports the requirement to record outcomes (B). The document does not mention any requirement to publish risks in a privacy notice.

4. Harvard University, Office of the Vice Provost for Research, "GDPR: Data Protection Impact Assessments (DPIA)": This university guidance outlines the DPIA process, stating, "The DPIA must... Describe the measures envisioned to address the risks... The DPIA report should be signed by the relevant DPO." This reinforces that C and B are required steps. It makes no mention of publishing risks in an information notice.