Privacy Impact Assessment Policy

As a registered charity, [Charity name] is committed to protecting personal data and respecting the privacy rights of individuals in accordance with data protection legislation and best practice.
This Privacy Impact Assessment (PIA) Policy sets out the Charity’s approach to identifying, assessing, and mitigating privacy and data protection risks arising from new or changed activities, projects, systems, or processes.

The Trustees recognise that conducting Privacy Impact Assessments is a key element of accountability, transparency, and lawful data processing.

Purpose of the Policy

1.1 The purpose of this Policy is to:

Ensure privacy risks are identified and addressed at an early stage.
Support compliance with UK data protection legislation.
Protect the rights and freedoms of individuals.
Promote a proactive and systematic approach to data protection.

1.2 This Policy provides a framework for when and how Privacy Impact Assessments should be carried out.

Scope of the Policy

2.1 This Policy applies to:

Trustees.
Employees.
Volunteers.
Contractors and third parties acting on behalf of the Charity.

2.2 It applies to all activities that involve the processing of personal data, including:

New projects, services, or programmes.
Significant changes to existing processes.
Introduction of new systems or technologies.
Data sharing with third parties.

Definition of a Privacy Impact Assessment

3.1 A Privacy Impact Assessment (PIA), also known as a Data Protection Impact Assessment (DPIA), is defined as:

A structured process for identifying and minimising the privacy and data protection risks of a project or activity involving personal data.

3.2 A PIA helps ensure that data protection considerations are embedded into decision-making and design.

Principles of Privacy Impact Assessments

4.1 The Charity’s approach to PIAs is guided by the following principles:

Lawfulness, fairness, and transparency.
Data minimisation and purpose limitation.
Privacy by design and by default.
Risk-based and proportionate assessment.
Accountability and documentation.

4.2 PIAs will be conducted openly and objectively.

When a Privacy Impact Assessment Is Required

5.1 A PIA must be considered where an activity is likely to:

Involve high-risk processing of personal data.
Introduce new technologies or systems.
Process sensitive or special category data.
Involve large-scale or systematic monitoring.
Significantly affect individuals’ rights or freedoms.

5.2 Where there is uncertainty, a precautionary approach will be taken.

Responsibility for Conducting PIAs

6.1 The Board of Trustees has overall responsibility for ensuring PIAs are undertaken where required.

6.2 Day-to-day responsibility for conducting PIAs may be delegated to:

A Data Protection Lead or Officer.
Senior managers responsible for the activity.

6.3 Accountability remains with the Trustees.

PIA Process

7.1 A PIA will typically include:

Description of the proposed activity or change.
Identification of personal data involved.
Assessment of necessity and proportionality.
Identification of privacy and data protection risks.
Measures to mitigate identified risks.

7.2 The process must be documented and retained.

Consultation and Stakeholder Involvement

8.1 Where appropriate, the Charity may:

Consult individuals or groups affected.
Seek specialist or legal advice.

8.2 Consultation supports transparency and informed decision-making.

Risk Mitigation and Decision-Making

9.1 Where risks are identified, the Charity will:

Implement appropriate safeguards.
Consider alternatives or changes to reduce risk.

9.2 Where high risks remain, decisions must be escalated to the Trustees.

Approval and Sign-Off

10.1 PIAs must be reviewed and approved by an authorised individual.

10.2 High-risk PIAs require Trustee oversight or approval.

Review and Updating of PIAs

11.1 PIAs will be:

Reviewed periodically.
Updated where there are changes to processing activities.

11.2 A PIA is a living document and must remain relevant.

Documentation and Record Keeping

12.1 Completed PIAs will be:

Retained securely.
Made available for audit or regulatory purposes if required.

12.2 Records will be kept in accordance with the Charity’s Records Retention Policy.

Training and Awareness

13.1 The Charity will:

Promote awareness of this Policy.
Provide training where appropriate.

13.2 Individuals involved in data processing must understand when a PIA is required.

Relationship with Other Policies

14.1 This Policy should be read in conjunction with:

Data Protection Policy.
Information Security Policy.
Records Retention Policy.
Incident Reporting Policy.

Monitoring and Review

15.1 This Policy will be reviewed:

At least annually, or
Following changes in law, guidance, or Charity activities.

15.2 Any amendments must be approved by the Board of Trustees.

Conclusion

By adhering to this Privacy Impact Assessment Policy, [Charity name] ensures that privacy and data protection risks are identified and addressed proactively, supporting lawful, fair, and transparent processing of personal data while protecting individual rights and maintaining public trust.

Signed: ………………………………………
Chair of the Board of Trustees

Date: ………………………………………

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