Does my AI system need a Data Protection Impact Assessment?
A Data Protection Impact Assessment (DPIA) under Art. 35 GDPR is mandatory when processing is likely to result in a high risk to the rights and freedoms of individuals. With AI systems, this is frequently the case: automated decision-making, profiling, processing of sensitive data, or large data volumes are typical triggers.
In practice, most production AI systems require a DPIA. We recommend conducting it early, not just before go-live. The DPIA documents risks and countermeasures and is one of the first documents requested during a supervisory authority review.
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