Data Protection Impact Assessment Policy
Effective date: September 12, 2023
1. Policy Statement
At Storebridger, we prioritize the protection of individuals' rights and privacy in alignment with data protection regulations. This Data Protection Impact Assessment (DPIA) Policy outlines our approach to identifying, assessing, and mitigating potential risks associated with data processing activities that may impact individuals' rights and freedoms. This policy reflects our commitment to transparency, accountability, and data protection across all our operations.
2. Scope
This policy applies to all data processing activities conducted by Storebridger, focusing on the development, implementation, and maintenance of our comprehensive business support tech solutions. It encompasses activities related to the collection, storage, sharing, and processing of personal and sensitive data.
3. Objectives
The objectives of this DPIA Policy are to:
- Identify potential risks to individuals' rights and freedoms resulting from data processing activities.
- Assess the necessity and proportionality of data processing for each project or initiative.
- Implement appropriate mitigation measures to minimize identified risks.
- Ensure compliance with relevant data protection regulations, including but not limited to Nigeria Data Protection Act 2023 and other applicable laws.
4. DPIA Process
4.1.
Identification of Data Processing Activities
Before commencing any new project, initiative, or significant alteration to existing processes, a preliminary assessment will be conducted to identify data processing activities warranting a DPIA.
4.2.
Risk Assessment
For identified data processing activities, a comprehensive DPIA will be conducted, scrutinizing potential risks to individuals' rights and freedoms, encompassing privacy, security, and compliance concerns.
4.3.
Necessity and Proportionality
Evaluating the necessity and proportionality of data processing ensures that collected data is pertinent and essential for its intended purpose, adhering to data minimization principles.
4.4.
Mitigation Measures
Appropriate mitigation measures, encompassing technical, organizational, and contractual safeguards, will be recommended based on the assessment of identified risks.
4.5.
Documentation
A DPIA report will be generated for each assessed data processing activity, outlining the assessment process, identified risks, mitigation measures, and conclusions.
5. Accountability and Review
- The Data Protection Officer (DPO) will oversee the DPIA process, ensuring compliance with data protection regulations.
- DPIAs will undergo periodic reviews and updates as needed, especially in response to changes in data processing activities, technology, or regulations.
6. Stakeholder Engagement
During the DPIA process, relevant stakeholders, including project teams, legal advisors, and privacy advocates, will be consulted to ensure a comprehensive risk assessment and the development of suitable mitigation strategies.
7. Transparency
Outcomes of DPIAs and related mitigation measures will be communicated transparently to data subjects and relevant authorities as mandated by applicable laws.
8. Training and Awareness
Employees engaged in data processing activities will receive training to comprehend the significance of DPIAs, the procedural framework, and their roles in upholding data protection.
9. Conclusion
By adhering to this Data Protection Impact Assessment Policy, Storebridger pledges to conduct data processing activities responsibly, with a strong emphasis on privacy considerations. We remain dedicated to safeguarding individuals' rights and adhering to data protection regulations.
Policy Owner: Storebridger
Policy Version: 1.0