DPDP Privacy Impact Assessment — Identify & Mitigate Data Risks

What is a Privacy Impact Assessment (PIA)?

A Privacy Impact Assessment is a structured process to identify and minimise privacy risks in a new project, system, or product before it launches. Under India's Digital Personal Data Protection (DPDP) Act 2023, conducting a PIA is considered best practice — and increasingly essential — before deploying any new data processing activity, especially those involving sensitive personal data, children's data, biometric records, or large-scale processing operations.

When is a PIA required under the DPDP Act 2023?

The DPDP Act 2023 does not yet mandate PIAs for every project, but the Significant Data Fiduciary (SDF) framework (Section 10) requires SDFs to conduct Data Protection Impact Assessments (DPIAs). For all other organisations, a PIA is strongly recommended whenever a new project involves high-risk data categories such as health records, biometric data, children's data, cross-border transfers, or automated decision-making. Enforcement is expected from May 2027.

What is the difference between a PIA and a DPIA?

A Privacy Impact Assessment (PIA) is the broader process that evaluates privacy risks across a project lifecycle. A Data Protection Impact Assessment (DPIA) is the formal regulatory version required for Significant Data Fiduciaries under DPDP Act Section 10. This tool helps you determine whether a PIA is required for your project — and produces a structured report that doubles as a DPIA framework for SDFs.

Who must conduct a PIA in India?

Any organisation classified or likely to be classified as a Data Fiduciary that launches new products, systems, or services involving personal data should conduct a PIA. Sectors most at risk include healthcare, HR/Payroll, ed-tech, fintech, e-commerce, and companies processing children's data. CA firms advising such clients should build PIA assessment into their DPDP compliance engagements.