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What is a DPIA and when do we need one?

Chris Duffy

Chris Duffy

Certified Chief AI Officer • • 2 Min Read

A DPIA, or Data Protection Impact Assessment, is a structured check you do before higher-risk processing of personal data. UK GDPR requires one when a use is likely to be high-risk, and a lot of AI use qualifies. It's a short document that names the risk, who it affects, and how you're reducing it.

You need one when you're doing something new or higher-risk with personal data: profiling people, processing at scale, or feeding sensitive data into a tool. If you're unsure whether a use crosses the line, that uncertainty is usually the signal to do one.

Done well, a DPIA takes a morning and saves you a far worse conversation later. It's also the kind of evidence a client's due diligence team likes to see. The ICO publishes a template; the work is in answering it truthfully for the AI tool you actually use.

Read next: Is AI use covered by UK GDPR · How to write an AI policy · Book a call

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Common questions

What is a DPIA and when do we need one?

A DPIA, or Data Protection Impact Assessment, is a structured check you do before higher-risk processing of personal data. UK GDPR requires one when a use is likely to be high-risk, and a lot of AI use qualifies. It's a short document that names the risk, who it affects, and how you're reducing it.

What goes in a DPIA for an AI tool?

What the tool does with the data, whose data it is, why the processing is necessary, the risks to those people, and the measures that reduce each risk: tier and retention settings, the data boundary, who can use it, and how you will check.

Chris Duffy, founder of Ignite AI Solutions

About the author

Chris Duffy Founder and Chief AI Officer, Ignite AI Solutions

Chris is the founder of Ignite AI Solutions, a Certified Chief AI Officer and one of the Top 20 AI Leaders of 2026. He is a regular expert source for Forbes on AI and cybersecurity, and a member of the UKAI Council supporting accredited pathways for upskilling. He was nominated for 3 awards at the National AI Awards 2026, including the Aiconics Award for responsible AI. A UK Special Forces veteran, he now helps UK SMEs adopt AI safely and effectively.

More about Chris · Chris in Forbes · LinkedIn · Substack

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