gdpr-pialisted
Install: claude install-skill roodlicht/accans-sec-skills
# AVG / GDPR Data Protection Impact Assessment
> **Disclaimer**: this is not legal advice. A DPIA is a legally sensitive document that exposes the organization to AP supervision and potentially civil claims. This skill structures the analysis; final qualifications (lawful basis, proportionality balancing, residual-risk acceptance) belong with the FG/DPO and/or privacy counsel.
## When to use
Art 35 AVG requires a Data Protection Impact Assessment (DPIA, in NL also "gegevensbeschermingseffectbeoordeling" or GEB) for processing operations posing a high risk to data subjects. This skill helps with the trigger check, drafting, and prior consultation of the AP when the residual risk remains high.
Triggers on:
- A question like "do we need a DPIA for this", "is this processing high-risk under the AVG", "help me draft a DPIA", "how do we do prior consultation with the AP", "DPIA template".
- A new or substantially changed processing of personal data: new SaaS introduction, AI/ML application that profiles, camera systems, biometrics, health data, large-scale data, employee monitoring, or processing in countries without an adequacy decision.
- A handoff from `risk-register` when privacy risk is part of it, or from `vendor-questionnaire` when a processor newly comes into scope.
- An FG/DPO question during supervisory or audit preparation.
### When NOT (handoff)
- Breach notifications (Art 33/34 AVG) → `ir-runbook` with a separate AP reporting procedure. DPIA is preventive, breac