What is a DPIA?
A Data Protection Impact Assessment (DPIA) is a structured process to identify and minimise data protection risks of a project, system or processing activity: mandated by GDPR Article 35 when processing is “likely to result in a high risk to the rights and freedoms of natural persons”. The KVKK has no express DPIA obligation; in practice, the data security duty in KVKK Article 12 and the Board’s required measures for special-category data lead controllers to run a comparable risk assessment for high-risk processing.
When a DPIA is required
- Systematic and extensive evaluation based on automated processing, including profiling.
- Large-scale processing of special-category data (health, biometrics, race, religion, political opinion).
- Systematic monitoring of publicly accessible areas on a large scale.
- New technologies with significant risk implications (AI systems, biometric ID, IoT).
- EDPB list: EDPB and member-state DPAs publish lists of processing requiring DPIA.
Required DPIA content (GDPR Article 35(7))
- Description of processing operations and purposes.
- Assessment of necessity and proportionality.
- Assessment of risks to data subjects.
- Measures to address risks (safeguards, security, mechanisms).
DPIA vs. related assessments
- DPIA vs. FRIA (AI Act): DPIA is data protection focused; FRIA is broader fundamental rights focused; both may apply.
- DPIA vs. TIA: Transfer Impact Assessment specifically for international transfers post-Schrems II.
- DPIA vs. privacy risk assessment: DPIA is the GDPR-defined formal version.
When a DPIA is required and how it is used
A Data Protection Impact Assessment is expected before processing that is likely to create a high risk to individuals: for example large-scale profiling, systematic monitoring of publicly accessible areas, processing of special-category data at scale, or the deployment of a new technology whose effects are not yet understood. The assessment documents the processing operation, tests its necessity and proportionality against the purpose, identifies the risks to data subjects, and records the measures chosen to reduce those risks. Where a high residual risk remains even after mitigation, prior consultation with the supervisory authority may be required before processing starts. A DPIA is not a one-off form: it is a living document that should be revisited whenever the purpose, scope, technology or risk profile of the processing changes.
DPIA in Turkish and cross-border practice
Under KVKK, the term “Data Protection Impact Assessment” is increasingly used, particularly in the compliance files of projects involving special-category data. For Turkish companies exporting to the EU market, the DPIA file is a standard compliance document shared with the EU-side controller or processor. Generic privacy risk assessments may not reach the GDPR Article 35 standard, so a document labelled as a risk assessment is not automatically a DPIA.
Sources. Regulation (EU) 2016/679 (GDPR) and Law No. 6698 on the Protection of Personal Data (KVKK). Statute links open the official consolidated Turkish texts on mevzuat.gov.tr.