The Spanish DPA (AEPD) issues a model report to help carry out data protection impact assessments for public administrations


The AEPD published in July 2019 a model report to help Public Administrations carry out im-pact assessments on data protection.

According to the DPA, this report compiles all such aspects that must be taken into account by any public body to prepare an impact assessment (DPIA), thereby complementing the Guidelines for Impact Assessments on Data Protection earlier published by the DPA.

The model report is further based on ISO-29134 "Guidelines for the impact assessment on privacy", ISO-31000 "Risk management. Principles and guidelines ”and ISO-31010“ “Risk management. Risk assessment techniques".

The model report has been developed in collaboration with the Ministry of Labor, Migration and Social Security and the Information Security Center of the Social Security Computing Management.

Among the obligations that the General Data Protection Regulation (GDPR) imposes on Da-ta Controllers is the need to assess the impact of data protection activities when it is proba-ble that such processing may pose a high risk for the rights and freedoms of data subjects.

The model collects all the aspects that must be taken into account in order to prepare an impact assessment report, among which is the description of the processing, the legal basis for processing, the analysis of the processing, the obligation to carry out an DPIA or compli-ance, as well as measures for the reduction of risk, an action plan and finally a section on conclusions and recommendations.

Although this model is not aimed at Controllers who carry out low-risk data processing, in those cases where it is not mandatory to make an impact assessment the controller may want to decide to carry out this analysis for other purposes, such as studying in depth a pro-cessing; improving the overall management of the processes of an organization; generating knowledge and culture of data protection, or exercising proactive responsibility and ac-countability.

The DPA model report can be accessed in Spanish here


Article provided by: Belén Arribas (Andersen Tax & Legal, Spain)


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INPLP is a not-for-profit international network of qualified professionals providing expert counsel on legal and compliance issues relating to data privacy and associated matters. INPLP provides targeted and concise guidance, multi-jurisdictional views and practical information to address the ever-increasing and intensifying field of data protection challenges. INPLP fulfils its mission by sharing know-how, conducting joint research into data processing practices and engaging proactively in international cooperation in both the private and public sectors.