Data Protection Impact Assessment, digma 4/2017

In the law journal digma 4/2017, Michael Widmer has published an essay on the data protection impact assessment (sometimes also called privacy impact assessment, PIA) as foreseen in the GDPR and the Swiss Draft for a revised Data Protection Act (Draft DPA). The essay also takes into account the guideline of the WP29. The article concludes that the Draft DPA still needs to be amended with regard to the rules on PIA, despite the adjustments which have been made in comparison with the preliminary draft. If the obligation to carry out a PIA or to consult the FDPIC (the Swiss federal data protection supervision authority) on this subject is too broad, this leads to a completely disproportionate and excessive burden on those responsible, without standing in a reasonable relation to the expected benefits.

The table of contents of digma 4/2017 is available here.

The journal can be obtained from Schulthess here or the articles can also be downloaded individually from Swisslex.