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Do we need a Data Protection Impact Assessment?

Reviewed by InfraVeritas360 ResearchFirst published Last reviewed

Sources: DPDP Act, 2023 and DPDP Rules, 2025 (MeitY)

Short answer: Required only for SDFs; good practice for high-risk changes

By law, only Significant Data Fiduciaries must do a yearly impact assessment. For everyone else it is good practice for high-risk changes: new tracking, profiling, large data sharing, children's data or moving data abroad. A short assessment before the change is cheaper than fixing it later.

Why it matters

Section 10 and Rule 13 require a yearly impact assessment for Significant Data Fiduciaries.

A worked example

A hospital plans to share imaging with a research partner abroad. A two-page assessment records the data, purpose, transfer and safeguards, and the DPO asks for de-identification first.

Steps

  1. Define what counts as a high-risk change for you.
  2. Use a two-page template.
  3. Record the data, purpose, risks and safeguards.
  4. Get the DPO's view before approval.
  5. Keep it with the project record.

Evidence to keep

Common mistakes

Who does what

What a good answer from management sounds like

“We assess high-risk changes before approval using a short template, and the DPO signs off.” Effort and time: Light per change.

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