Review/Updating

When Should a DPIA Be Reviewed or Updated?

GDPR Article 35(11) requires a DPIA to be reviewed and updated whenever there is a change in risk related to processing activities. Risk changes can stem from:

Guidance from Authorities

WP29

adds that DPIAs should be reviewed “regularly” and “periodically” but does not define a timeframe.

CNIL (France) & Slovenian SA

Maximum 3-year review period to ensure risks remain acceptable.

Dutch Authorities Persoonsgegevens

Suggests 3 years as an example of an appropriate review cycle.

Finnish SA

Emphasizes ongoing monitoring of risk levels after processing begins.

Luxembourg SA

Focuses on risk increases as a primary trigger for a DPIA update.

Key Takeaways

By regularly reviewing and updating DPIAs, organizations can maintain compliance, manage risks effectively, and adapt to evolving data protection challenges.