Assessment of potential risks and possible mitigations Principle 1 : Purpose of collection of personal information Ref. no. Purpose of collecting the information Description of the risk Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual current risk Recommended mitigations or privacy enhancements Residual risk remaining despite new safeguards Identify each aspect of the project that raises privacy issues Describe any vulnerability and the risk identified (that is, that could upset the project) noting any relevant legal rules and system design needs Explain why this is an issue; the potential adverse impact on individuals (or the agency) and the benefit that you wish to continue to achieve Document the systems and safeguards currently in place that act to minimise these identified risks Assess the likelihood of the risk eventuating (high, medium or low) and how severe the harm would be with no new protections (serious to minimal) Include recommendations for how these residual risks can be removed, managed, or mitigated, or further privacy safeguards to ensure the individual is protected Detail any remaining vulnerabilities in the design that need to be managed. Note risk level (high, medium or low) and the likely severity of harm without any new safeguards.
EXAMPLE ONLY - See “How to do a PIA” for more information Ref. no. Purpose of collecting the information Description of the risk Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual current risk Recommended mitigations or privacy enhancements Residual risk remaining despite new safeguards R-001 What personal information the app collects The app will collect more information than is specified in the privacy statement App will have greater functionality and lead to increased monetisation, but app users may object to collection beyond current privacy policy and collection may breach law Business has a purpose for collecting the further personal information but app policy does not currently reflect it Medium/Moderate Put in place a process to manage clear notification and consent for greater collection by app once purposes change Low / Minimal Some existing customers may still not realise the change has occurred Privacy Impact Assessment – Risk and Mitigation Table
Principle 4: Manner of collection of personal information Ref. no. How you are collecting personal information Description of the risk identified Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual (current) risk recognising current measures Recommended additional actions to reduce or mitigate risk Residual risk remaining despite new safeguards Principle 5: Storage and Security of personal information Ref. no. How you are storing and securing personal information Description of the risk identified Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual (current) risk recognising current measures Recommended additional actions to reduce or mitigate risk Residual risk remaining despite new safeguards Principles 6 and 7: Access to and correction of information
Ref. no. Responding to people’s requests for information about themselves, or requests to correct information about themselves Description of the risk identified Rationale and consequences for the agency or individual Existing controls that contribute to manage identified Assessment of residual (current) risk recognising current measures Recommended additional actions to reduce or mitigate risk Residual risk remaining despite new safeguards Principle 8: Accuracy etc. of personal information to be checked before use Ref. no. What steps do you take to check the accuracy, relevance etc of personal information before you use it? Description of the risk identified Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual (current) risk recognising current measures Recommended additional actions to reduce or mitigate risk Residual risk remaining despite new safeguards Principle 9: Agency not to keep personal information for longer than necessary
Ref. no. Why do you need a unique identifier, and are you allowed to use this one? Description of the risk identified Rationale and consequences for the agency or individual Existing controls that contribute to manage risks identified Assessment of residual (current) risk recognising current measures Recommended additional actions to reduce or mitigate risk Residual risk remaining despite new safeguards