Do I need to run a DPIA?
A DPIA is mandatory for processing with high risk to data subjects. The AP publishes a list, start there.
support/compliance-en-wetgeving/dpia-verplicht-of-nietsteps: 5
Try this first
- Check the AP DPIA list. If your processing is on it, DPIA is mandatory.
- Also walk the WP29 nine criteria (scoring, automated decisions, systematic monitoring, special-category data, large scale, dataset combining, vulnerable subjects, novel tech, blocking of rights). Two or more hits means: run one.
- Use a fixed template. Description, necessity, risk analysis, measures, residual risk. AP and NOREA templates work.
- Involve the DPO if you have one; their advice belongs in the document.
- Keep it as a living document, updated when the processing changes.
When to bring us in
High residual risk after measures means prior consultation with the AP. That is not a formality. Let us scope it first.
See also
- Does NIS2 apply to my company?Two questions decide it: are you in a listed sector, and do you meet the threshold from Recommendation 2003/361/EC (more than 50 FTE and more than EUR 10M turnover or balance sheet). Below that you are only indirectly in scope, via your customers. The threshold determines whether you are an important or essential entity depending on sector.
- What changes with the Dutch Cyber Security Act?The Cyberbeveiligingswet is the Dutch implementation of NIS2. Track NCSC for the exact effective date and the lower regulations.
- Am I personally liable as a director under NIS2?Yes. The board is accountable for approving and overseeing the cyber measures. Severe negligence can become personal.
None of the above fits?
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