Data Protection Impact Assessments Without the Drama
Data Protection Impact Assessments (DPIAs) protect patients, reassure regulators, and keep change projects on track. A disciplined workflow makes the process feel routine rather than disruptive.
Know when to start
- New digital tools, telehealth platforms, or shared analytics projects that add or change data flows.
- Expanded remote monitoring, cloud storage, or third party processing arrangements.
- Processing of new categories of sensitive staff data, such as health surveillance or wellbeing programmes.
- Any change flagged by the DPO, Caldicott Guardian, or practice manager as potentially high risk.
Work through four clear stages
- Screen: Run a short trigger checklist. If risks to individuals are likely, start the full DPIA straight away.
- Discover: Map data sources, lawful bases, special category conditions, recipients, and retention periods. Capture unanswered questions and dependencies.
- Evaluate: Describe threats, estimate likelihood and impact, and record planned mitigations such as role based access, minimisation, or encryption.
- Sign off and monitor: Agree actions, set review dates, secure signatures from senior leads, and add tasks to project plans so nothing slips.
Engage the right people
- Invite frontline staff to describe how the change affects their daily processes. This uncovers hidden risks quickly.
- Involve IT or supplier contacts to validate technical controls and support timely responses.
- Share draft findings with the project team early so they can shape mitigations rather than learn about them at the end.
Keep evidence organised
- Store the approved DPIA, risk matrix, and action tracker in a controlled location with version history.
- Retain supporting notes such as meeting minutes, supplier assurance letters, and training plans.
- Record when actions complete and link to incident logs or change requests that show the mitigations in use.
Review after go live
- Check that actions agreed in the DPIA have been completed within the planned timeframe.
- Monitor incidents, near misses, and patient feedback for evidence that residual risks are acceptable.
- Plan a formal refresh when the system or processing changes, or at least every two years.
Put it into practice
Choose the next project on your change pipeline and run through the screening step today. If a DPIA is required, book the discovery workshop and brief the team on the four stages. Highlight how premium templates, risk libraries, and training packs can streamline future assessments once the practice has confidence in the workflow.
Disclaimer
This guidance is for general information. It is not a substitute for legal, clinical, or specialist advice. Always seek professional support tailored to your practice.