DPIA checklist for workforce monitoring
A DPIA is a process, not a badge. It should demonstrate how the proposed monitoring was tested, challenged, reduced and approved before high-risk processing starts.
Make the process easier to understand and question.
Describe the processing
Document the purpose, data sources, frequency, people affected, information flow, recipients, storage locations and retention. Identify where AI is used.
Test necessity and proportionality
Connect each data item to the purpose. Record alternatives considered and explain why the selected settings are the least intrusive effective approach.
- Lawful basis and employment-law considerations
- Transparency and consultation plan
- Data minimisation and retention limits
Assess risks to people
Consider chilling effects, unfair inferences, discrimination, inaccurate classification, loss of confidentiality, excessive manager access and the consequences of a breach.
Record safeguards
Assign controls, owners and dates. Include human review, challenge routes, role-based access, security measures, training, supplier terms and audit checks.
Approve and revisit
Record residual risk and accountable approval. Consult the ICO before processing if a high residual risk cannot be reduced. Review after changes or incidents.