DPIA for AI: When You Need One and How to Write One Quickly
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A Data Protection Impact Assessment (DPIA) under GDPR Article 35, combined with a Fundamental Rights Impact Assessment (FRIA) under EU AI Act Article 27, is the single biggest piece of compliance work for high-risk AI use. It is also the one SMBs over-think.
When you need a DPIA + FRIA
- Hiring or HR AI (CV screening, candidate ranking, performance assessment).
- Credit or insurance AI affecting individuals.
- AI in education access decisions (admissions, grading, scholarships).
- Healthcare AI affecting patient pathways.
- AI determining access to public services.
- Biometric identification or categorisation.
- Any AI processing special category data (health, biometric, racial/ethnic, religious, sex life).
The 90-minute template
A complete SMB-sized DPIA + FRIA covers: identification, purpose and context, data inventory, risk assessment, fundamental rights impact, affected persons and stakeholders, human oversight, individual rights, monitoring, conclusion and sign-off.
What residual risk means
After mitigations, your DPIA assigns a residual risk level: low, medium, high, or unacceptable. Low or medium: proceed. High: senior management approval required, possible DPA consultation. Unacceptable: do not deploy.
Done-for-you DPIA + FRIA
The Ready AI Act Premium Compliance Programme (€899) includes a DPIA + FRIA for one of your high-risk use cases — completed by us within 5 business days, reviewed by qualified ICT/privacy counsel, ready for management sign-off.