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Privacy Impact Assessments for Businesses

In today’s data-driven world, businesses collect, store and process more personal information than ever before. With increasing scrutiny from regulators and rising expectations from customers, privacy can no longer be an afterthought. A Privacy Impact Assessment (PIA) is a powerful tool that helps organisations identify, manage and mitigate privacy risks before they become costly problems.

In this article, our privacy and data lawyers explain what PIAs are, why businesses need them, how they work, and when to conduct one. We’ll also walk through a real-life example and answer common questions.

Key Takeaways

  • A PIA is a structured process to assess how a project or system affects personal data privacy.

  • PIAs are crucial for compliance with privacy laws like the Privacy Act 1988 (Cth) and the GDPR.

  • They help businesses build trust, reduce risk, and demonstrate accountability.

  • PIAs should be conducted before new projects, systems, or data-sharing arrangements go live.

  • A step-by-step approach ensures businesses identify risks early and design privacy into their processes.

Farrah Motley is the Legal Practice Director of Prosper Law and a highly experienced lawyer

What is a Privacy Impact Assessment?

A PIA is a risk management tool that evaluates how a business activity, system or project might impact the privacy of individuals.

It involves:

  1. Describing the initiative: what data will be collected, used or shared.

  2. Identifying privacy risks: such as data breaches, over-collection of information, or third-party misuse.

  3. Assessing compliance obligations:  ensuring alignment with relevant privacy legislation and industry standards.

  4. Recommending safeguards: introducing controls, policies or technologies to reduce risk.

Think of it as a privacy “health check” for your business initiatives.

To stay ahead of recent regulatory changes, check out our article on the New Privacy Laws in Australia – 2025, which explains how updated rules affect consent, penalties and compliance requirements.

Why Businesses Need Privacy Impact Assessments

Businesses should conduct PIAs for a number of reasons, including:

1. Legal and Regulatory Compliance

Australian businesses are subject to the Privacy Act 1988 (Cth) and, in some cases, international laws such as the General Data Protection Regulation (GDPR). Conducting a PIA helps demonstrate compliance and avoid penalties.

2. Risk Reduction

Privacy breaches can result in reputational damage, customer loss and significant financial penalties. A PIA identifies risks before they cause harm.

3. Customer Trust and Transparency

Businesses that proactively manage privacy concerns show clients and customers that their data is taken seriously, an increasingly powerful competitive advantage.

4. Cost Efficiency

Fixing privacy issues after a project has launched is costly. PIAs allow you to build privacy measures into the design, saving money and reducing delays.

For practical guidance on preparing for worst-case scenarios, see our Data Breach Response Plan Checklist to ensure your business is ready to respond swiftly and effectively.

How to Conduct a Privacy Impact Assessment

A practical framework for businesses includes:

  1. Plan and scope: define the project and the data involved.

  2. Describe information flows: map how personal data is collected, used, stored and shared.

  3. Identify privacy risks: look for potential harms or legal issues.

  4. Consult stakeholders: engage with staff, customers, or regulators if appropriate.

  5. Evaluate and mitigate risks: propose safeguards like encryption, limited access, or updated policies.

  6. Document and review: create a formal PIA report and keep it updated as projects evolve.

Real-Life Example: Retailer Implementing a Customer Loyalty Program

A national retailer wanted to launch a customer loyalty program that collected purchase history, contact details, and shopping preferences.

The PIA revealed:

  • Collecting date of birth was unnecessary and created extra privacy risks.

  • Storing purchase history indefinitely was non-compliant with data retention obligations.

  • Third-party marketing partners posed risks around uncontrolled data sharing.

Mitigation measures included:

  • Removing date of birth from mandatory sign-up fields.

  • Limiting data retention to two years.

  • Revising contracts with third-party partners to include stricter privacy obligations.

Result: The retailer avoided a potential regulatory breach, improved customer trust, and launched the program smoothly.

Allison Inskip is a Senior Paralegal and highly experienced legal professional

Frequently Asked Questions (FAQs)

When Should a Privacy Impact Assessment Be Conducted?

A PIA should be carried out when a project:

  • Involves new technology or systems that collect or process personal information.

  • Introduces new ways of using, storing or sharing data.

  • Involves sensitive information, such as health or financial records.

  • Creates large-scale data processing or data matching activities.

  • May raise community or stakeholder concerns about privacy.

In short: if your project touches personal data in a significant way, it’s time to run a PIA.

Are PIAs legally required?

Not always, but they are strongly recommended under the Australian Privacy Principles (APPs) and often required under GDPR for high-risk data processing.

Who should conduct a PIA?

Ideally, a PIA should be carried out by privacy professionals or legal advisors, often in collaboration with IT and compliance teams.

How long does a PIA take?

Depending on complexity, a PIA can take anywhere from a few days to several weeks. Early planning helps streamline the process.

Can small businesses benefit from PIAs?

Yes. Even if not legally required, small businesses can use PIAs to identify risks, build customer trust, and avoid costly mistakes.

What happens if we don’t do a PIA?

You risk non-compliance with privacy law, exposure to data breaches, and loss of customer trust – all of which can be far more costly than conducting a PIA.

A Privacy Impact Assessment isn’t just a compliance exercise – it’s a smart business strategy. By identifying risks early, demonstrating accountability, and embedding privacy into your operations, your business can strengthen customer trust, reduce legal risk, and operate more efficiently.

If your organisation is planning a project that involves personal data, engaging legal professionals like Prosper Law can help ensure your PIA is comprehensive and compliant.

About the Author

Farrah Motley
Director of Prosper Law. Farrah founded Prosper online law firm in 2021. She wanted to create a better way of doing legal work and a better experience for customers of legal services.

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