Mastering the Trickiest GDPR Exercise: DPIAs Done Right

Everyone knows they need DPIAs. Actually doing them properly? That turns out to be genuinely hard.

Article 35 of GDPR sounds straightforward enough: assess risks before processing personal data. But the reality is messier than the regulation suggests. You need to document your processing activities, identify risks to individuals, evaluate whether your approach is necessary and proportionate, and then keep track of every third-party processor who touches that data.

Most companies handle this in one of three ways:

• Use a template that ticks boxes but proves nothing meaningful
• Pay consultants thousands to do it for them
• Complete one assessment and never look at it again

None of these approaches survive serious regulatory scrutiny. When the ICO comes knocking, they want to see a living process, not a dusty document.

What We Built

We have added full data privacy assessment capability to RateYourCyber. Here is what it includes.

Privacy Risk Assessment

Comprehensive GDPR compliance checking across all your processing activities. Not just a checklist, but actual gap analysis with plain English explanations of what each finding means for your organisation. Risk scoring aligns to ICO enforcement priorities, so you know which issues to tackle first.

DPIA Screening and Documentation

The first question most people get wrong: do you actually need a DPIA? Our guided screening walks you through the criteria. When you do need one, the full assessment workflow captures everything and records it for accountability. No more wondering whether your documentation would hold up.

Third-Party Processor Assessment

This is where most organisations really struggle. You can send a secure questionnaire to any processor. It covers 35 questions across 10 Article 28 compliance domains. The plain English toggle means processors actually understand what they are being asked, which dramatically improves response quality.

The processor assessment questionnaire with plain English explanations enabled

Once they complete it, you get automated risk analysis with specific recommendations. Professional reports you can actually defend if questions arise.

Assessment results with executive summary, key findings, and category-by-category scoring

Why Plain English Matters So Much

GDPR was written by lawyers for lawyers. Your processors are not lawyers. Neither are most of the people completing internal assessments.

Consider this actual GDPR requirement:

Legal language: "processes the personal data only on documented instructions from the controller, including with regard to transfers to third countries or an international organisation"

Plain English: "You only process personal data as the controller has documented in writing, including any international transfers they have specifically authorised."

When processors understand the questions, they give you better answers. When they give better answers, you get more accurate risk assessments. When your risk assessments are accurate, you make better decisions about who to work with and what controls to require.

What You Actually Get

The output is not just scores. It is decisions.

• Low risk processor: standard DPA terms are sufficient, proceed with normal monitoring
• Medium risk: enhanced monitoring required, specific contractual provisions needed
• High risk: do not engage without remediation plan, escalate before proceeding

Detailed category breakdown with recommended actions for each compliance gap

The Bottom Line

Your data protection is only as strong as your evidence. Regulators do not care about good intentions. They want documentation that shows you identified risks, assessed them properly, and took appropriate action.

Build the evidence before you need it.

Who Needs This

If you process personal data and work with any external suppliers, you probably need better DPIA processes than you currently have. That includes:

• Any organisation using cloud services - your cloud providers are processors under GDPR
• Companies with customer databases - especially if you share data with marketing platforms, analytics tools, or CRM systems
• Healthcare and financial services - where processing often involves special category data
• Organisations expanding into new markets - international transfers trigger additional DPIA requirements
• Anyone who has been putting this off - regulators are getting less patient

The ICO issued record fines last year. Their enforcement priorities are clear: they want to see documented, systematic approaches to data protection. Ad hoc compliance is not compliance.