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2. Is a separate DPIA required each time this occurs? The spreadsheet provided as a template doesn't seem to speak to these events
Answers:
1. According to EU GDPR article 35 – “ Data protection impact assessment” (https://advisera.com/eugdpracademy/gdpr/data-protection-impact-assessment/) a DPIA is required if you are processing “personal data relating to criminal convictions and offences”. Although the EU GDPR also mentions that the processing activity would need to be on a “large scale” I would strongly advise you to perform an DPIA for background checking prior to employment.
2. You don’t need a DPIA each time you do a background check you can just mention the background checking as processing activity and this would cover all the cases you do a background check provided that you process the same data in a similar way.
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Mar 21, 2018