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Data Protection Risk Assessment

Data Protection Risk Assessment Template for Philippines

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Key Requirements PROMPT example:

Data Protection Risk Assessment

"I need a Data Protection Risk Assessment for our new cloud-based healthcare records management system being implemented in March 2025, focusing particularly on sensitive medical data handling and compliance with Philippine healthcare regulations."

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Document background
The Data Protection Risk Assessment is a mandatory requirement under the Philippines Data Privacy Act of 2012 for organizations processing personal information. This document is required when implementing new systems, processes, or significant changes that involve personal data processing. It helps organizations identify and mitigate privacy risks, ensure compliance with Philippine privacy laws, and demonstrate accountability to the National Privacy Commission. The assessment must be conducted periodically or when there are significant changes to data processing activities, making it a crucial tool for ongoing privacy compliance and risk management.
Suggested Sections

1. Executive Summary: High-level overview of the assessment findings, key risks identified, and major recommendations

2. Scope and Objectives: Definition of the assessment scope, including systems, processes, and data types being evaluated

3. Description of Processing Activities: Detailed inventory of personal data processing activities, including purpose, nature, and scope of processing

4. Legal Basis and Compliance Requirements: Analysis of applicable legal requirements under the Data Privacy Act and other relevant regulations

5. Data Flow Analysis: Mapping of how personal data flows through the organization, including collection, processing, storage, and disposal

6. Risk Assessment Methodology: Description of the approach and criteria used to identify and evaluate privacy risks

7. Risk Identification and Analysis: Detailed analysis of identified risks, their likelihood, and potential impact on data subjects

8. Current Controls Assessment: Evaluation of existing technical and organizational measures for data protection

9. Gap Analysis: Identification of areas where current controls fall short of requirements or best practices

10. Recommendations and Action Plan: Proposed measures to address identified risks and gaps, including timeline and responsibilities

Optional Sections

1. International Data Transfers: Assessment of cross-border data transfers and associated risks (include when international data transfers are involved)

2. Vendor Assessment: Evaluation of third-party service providers' data protection practices (include when external processors are used)

3. Special Categories of Data: Specific assessment for sensitive personal information (include when processing sensitive personal data)

4. Business Continuity and Disaster Recovery: Assessment of data protection measures in BC/DR plans (include for critical systems)

5. Privacy by Design Assessment: Evaluation of privacy considerations in system design (include for new systems or major changes)

Suggested Schedules

1. Data Inventory Matrix: Detailed listing of all personal data elements processed, including classification and retention periods

2. Risk Assessment Matrix: Detailed risk scoring and evaluation matrix with specific scenarios and impact levels

3. Control Framework Checklist: Comprehensive checklist of technical and organizational measures evaluated

4. Data Flow Diagrams: Visual representations of data flows within and outside the organization

5. Action Plan Timeline: Detailed timeline for implementing recommended controls and improvements

6. Compliance Documentation: Copies of relevant policies, procedures, and compliance certificates

7. Interview and Assessment Records: Documentation of stakeholder interviews and assessment activities conducted

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Personal Data
Processing
Data Subject
Data Protection Officer
Personal Information Controller
Personal Information Processor
Sensitive Personal Information
Data Protection Impact Assessment
Privacy Risk
Risk Level
Control Measures
Data Breach
Consent
Data Transfer
Privacy Notice
Information Security
Data Processing System
Cross-border Transfer
Technical Measures
Organizational Measures
Security Incident
Privacy Impact
Likelihood
Risk Treatment
Residual Risk
Data Flow
Processing Activity
Data Retention
Data Disposal
Automated Processing
Manual Processing
Privacy Framework
Compliance Requirements
Mitigation Measures
Data Classification
Privacy Management Program
Data Protection Principles
Privacy by Design
Privacy by Default
Records of Processing Activities
Legitimate Interest
Lawful Processing
Assessment Methodology
Risk Criteria
Risk Matrix
Clauses
Scope and Purpose
Assessment Methodology
Data Processing Activities
Risk Assessment
Data Subject Rights
Security Measures
Cross-border Transfers
Breach Management
Accountability Measures
Technical Controls
Organizational Controls
Third Party Management
Training and Awareness
Data Retention
Compliance Requirements
Risk Mitigation
Monitoring and Review
Documentation Requirements
Incident Response
Privacy Impact
Sensitive Data Handling
Access Control
Data Minimization
Consent Management
Privacy Notices
Record Keeping
Audit and Assessment
Business Continuity
Change Management
Regulatory Reporting
Relevant Industries

Banking and Financial Services

Healthcare and Medical Services

Technology and Telecommunications

Education

Retail and E-commerce

Business Process Outsourcing

Insurance

Government and Public Sector

Manufacturing

Professional Services

Real Estate

Transportation and Logistics

Hospitality and Tourism

Relevant Teams

Legal and Compliance

Information Security

Risk Management

Information Technology

Data Privacy

Internal Audit

Operations

Human Resources

Project Management Office

Business Analysis

Quality Assurance

Data Governance

Corporate Security

Enterprise Architecture

Regulatory Affairs

Relevant Roles

Data Protection Officer

Chief Information Security Officer

Privacy Manager

Compliance Officer

Risk Manager

IT Security Manager

Legal Counsel

Chief Technology Officer

Information Security Analyst

Privacy Analyst

Compliance Specialist

Risk Assessment Specialist

Data Protection Specialist

Information Security Consultant

Privacy Impact Assessment Officer

Industries
Republic Act No. 10173: Data Privacy Act of 2012 - The primary legislation governing personal data protection in the Philippines, establishing the rights of data subjects and obligations of personal information controllers and processors
Implementing Rules and Regulations of the Data Privacy Act of 2012: Detailed regulations that implement the Data Privacy Act, providing specific requirements for compliance, including security measures and data breach notification procedures
NPC Circular No. 16-01: Security of Personal Data in Government Agencies - Provides guidelines for government agencies processing personal data
NPC Circular No. 2016-03: Personal Data Breach Management - Outlines the procedures for handling and reporting personal data breaches
Republic Act No. 8792: Electronic Commerce Act of 2000 - Relevant for data protection in electronic transactions and digital signatures
NPC Circular No. 2020-03: Guidelines on Security of Personal Data in a Work-From-Home Arrangement - Specific guidelines for protecting personal data in remote work settings
NPC Privacy Toolkit: Official guidance document from the National Privacy Commission providing templates and procedures for privacy impact assessments
NPC Circular No. 2016-01: Security of Processing Personal Information - Provides guidelines on security measures for personal data processing
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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