DPIAs should clearly record risks, mitigations, decisions, and DPO advice in a structured and repeatable way.

Why this matters

DPIAs are often reviewed during investigations, complaints and after change.

What a defensible DPIA includes

• Description of processing and purpose
• Assessment of necessity, proportionality and compliance
• Identified risks to individuals
• Mitigation measures
• DPO advice and sign‑off

Common DPIA weaknesses

• Vague risk descriptions
• Missing DPO input
• No review or follow‑up

What good looks like

DPIAs that show reasoned decision‑making, not box‑ticking.