Analysing Privacy Risks in a DPIA: Impact, Likelihood & Overall Rating
A DPIA evaluates privacy risk by assessing two dimensions: the impact on individuals if harm occurs and the likelihood that the incident will materialize. Combining both gives an overall risk rating so teams can prioritize mitigation before launch.
Privacy risks refer to potential harm to Data Principals when personal data is misused, breached, or processed without safeguards. Harm may involve financial loss, discrimination, loss of autonomy, or even threats to safety. A structured, repeatable methodology ensures accountability, compliance, and trust.
Step-by-Step Method to Analyse DPIA Risks
1. Assess the Impact
Impact measures how severe the harm could be if the risk materializes. Categorizing impact helps stakeholders understand consequences for individuals and regulatory exposure.
| Impact Level | Description |
|---|---|
| Minor | Minimal inconvenience or temporary discomfort |
| Moderate | Noticeable negative effect, reputational or emotional impact |
| Major | Significant harm such as discrimination, financial loss, identity theft |
| Severe / Critical | Endangers life, safety, or causes irreversible damage |
2. Assess the Likelihood
Likelihood measures how probable it is for the incident to occur, given the environment and controls.
| Likelihood Level | Examples |
|---|---|
| Rare | Very unlikely due to strong controls |
| Possible | Could occur under certain situations |
| Probable | Likely to occur as part of normal processing |
| Almost Certain | Expected to happen frequently |
3. Combine Impact & Likelihood to Calculate Risk Rating
Use a risk matrix to determine overall severity. For example, Impact = Major and Likelihood = Probable results in a High risk, requiring urgent mitigation before go-live.
| Likelihood ↓ / Impact → | Minor | Moderate | Major | Severe |
|---|---|---|---|---|
| Rare | Low | Low | Medium | Medium |
| Possible | Low | Medium | Medium | High |
| Probable | Medium | Medium | High | High |
| Almost Certain | Medium | High | High | Critical |
4. Decide Required Actions
| Risk Rating | Action Required |
|---|---|
| Low Risk | Acceptable — monitor |
| Medium Risk | Improve controls & review by Data Protection Officer |
| High Risk | Must be mitigated before processing continues |
| Critical Risk | Processing must not begin until fully redesigned |
Risk Mitigation Strategies
- Strengthen encryption, access control, and monitoring.
- Minimize data collected and shorten retention timelines.
- Apply pseudonymization or anonymization for analytics.
- Schedule third-party security reviews and penetration tests.
- Re-run DPIAs after major technology or process changes.
Why This Matters
A predictable risk analysis process reinforces DPDP compliance, demonstrates accountability, and protects individuals from harm while enabling safer digital innovation.
Key Takeaway
Impact × Likelihood = Risk Rating. High and Critical risks must always be mitigated before launch—only monitor Low risks, and ensure Medium risks receive targeted controls and DPO review.
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