Support for a risk assessment in the form of a GDPR compliant Data Protection Impact Assessment (DPIA).
Privacy assessment that helps you build, launch and scale
A Data Protection Impact Assessment should not be a document produced shortly before launch simply to tell a product team whether it can proceed.
Done well, a DPIA is a product and business decision tool.
It helps you understand privacy risk early, make better design decisions, introduce the right safeguards and find a commercially workable route to launch and scale.
Sharp Cookie Advisors works alongside product, technology, security, business development, sales and legal teams throughout this process.
Our objective is not simply to identify risk - We help you find a way forward.
Not every new processing activity, AI tool, technology vendor or system change requires a full Data Protection Impact Assessment (DPIA).
We help organisations determine what level of assessment is actually proportionate to the change and the risks involved. In some cases, a focused privacy risk assessment with clear safeguards, go-live conditions and risk ownership is sufficient. In others, the GDPR requires a full DPIA.
Our assessment considers how the solution works in practice, including its purposes, data flows, categories of personal data, access model, vendors and subprocessors, international transfers, use of new technologies and potential impact on individuals.
The objective is not simply to identify risk, but to give management, legal, technology and security teams a clear and documented basis for deciding what can proceed, what needs to change before go-live and when further assessment is required.
Technology develops iteratively. AI models improve. Features change. New data sources are connected. Human review may be reduced as automation becomes more reliable. Products move into new markets and early assumptions are tested against actual use.
A useful DPIA needs to work with that reality.
We therefore treat the DPIA as a living decision framework rather than a one-off compliance document.
Depending on the project, we can help you:
The result should be privacy by design that works in the actual product – not merely on paper.
Not every project needs the same level of privacy analysis or documentation.
We normally start with an initial triage to understand the technology, intended use, data involved, affected individuals, and the business decision to be made.
From there, we calibrate the assessment to the actual risk and purpose.
For lower-risk or early-stage initiatives, a focused privacy assessment may be sufficient.
We identify the key privacy issues, material gaps and practical actions needed to move forward – without turning the exercise into a full-scale DPIA where one is not required.
A Privacy Snapshot can be particularly useful during early product development, procurement, pilots or where a team needs a qualified privacy position before investing further.
Where the risk is concentrated around particular issues, or an existing product or assessment is changing, we can focus the analysis accordingly.
This may be appropriate when introducing a new AI component, changing data use, expanding functionality, reducing human oversight, adding a new vendor or market, or making another material change to an existing processing activity.
The objective is a proportionate assessment and decision record rather than unnecessarily reopening every aspect of an established DPIA.
For complex or high-risk processing, we conduct a comprehensive DPIA designed to withstand serious scrutiny.
This typically involves closer work with product, technology, security, business and legal stakeholders; detailed analysis of necessity, proportionality, risks and safeguards; and a documented basis for management decisions and residual-risk acceptance.
The assessment can be prepared with its expected audience in mind – including internal governance bodies, sophisticated enterprise customers and, where relevant, potential review by the Swedish Authority for Privacy Protection (IMY) or another supervisory authority.
The difference is not simply the number of pages. The level of analysis, evidence and documentation should reflect the risk, the decision being made and who may ultimately scrutinise the assessment.
We support DPIAs from both sides of the technology relationship.
You may be developing a new AI, SaaS, IoT or data-driven product and need to understand how privacy requirements affect its design and route to market.
Or you may be purchasing or deploying new technology and need to understand what its use means for your customers, employees or other individuals – and what you need from the supplier before going live.
In both cases, we focus on the actual technology, data flows and intended use rather than applying a generic compliance template.
Privacy risk is rarely best managed through a binary choice between stopping a project and accepting every identified risk.
Where legally appropriate, we help clients determine whether a controlled launch can provide a better route forward.
Depending on the product, this could mean:
The conditions are specific to the technology and risk.
The important point is that they are deliberate, measurable and documented.
For suitable products, the DPIA can establish the framework for a controlled first release and subsequent scale-up.
Before launch, we can help define what needs to be monitored – for example, accuracy, human escalations, complaints, unexpected outcomes, false positives or negatives, security events or other product-specific risk indicators.
Actual product performance can then inform the next risk decision.
Where safeguards work and agreed indicators develop as expected, functionality, traffic or geographical coverage can be expanded. Where they do not, the product can be adjusted before exposure becomes significantly larger.
Privacy governance becomes part of the product feedback loop.
This approach can be particularly valuable for AI, automated decision-making, profiling and other technologies where risk depends partly on how the product performs in real-world use.
Under the GDPR, a DPIA is required where processing is likely to result in a high risk to individuals’ rights and freedoms.
Not every technology project, therefore, requires a full DPIA. Part of our role is helping you determine the appropriate level of assessment.
We frequently advise on projects involving:
We support organisations when introducing AI and SaaS solutions, new analytics or customer platforms, integrations and connectors, profiling and automated processing, international data flows, or material changes to existing processing.
We can also help at an earlier stage to determine whether a DPIA is required at all and what level of documentation is proportionate to the decision.
The best DPIAs are not produced by lawyers working in isolation.
We add specialist technology and data-protection expertise, independent challenge and experience translating complex privacy requirements into product and commercial decisions.
We can lead a complex DPIA, support an existing legal or privacy function with specialist expertise, or provide independent DPO advice where required.
Our role is to complement the people who already understand the business – not replace them.
Our work does not need to end when the DPIA document is complete.
We can support the complete process – from initial screening and stakeholder workshops through the DPIA and privacy-by-design work to technical and organisational safeguards, supplier or customer negotiations, DPAs, launch conditions and post-launch monitoring.
For technology suppliers, a well-run DPIA and privacy-by-design process can also support enterprise sales by giving sophisticated customers a clear and defensible explanation of how privacy risk has been addressed.
Depending on the situation, the appropriate output may be a concise privacy risk and decision note, a targeted privacy review, a transfer impact assessment (TIA), or a full DPIA with documented risks, safeguards, actions and residual risk.
The assessment is scaled to the decision – providing enough governance and documentation to support a defensible outcome without turning every technology or data initiative into a major compliance project.
For organisations handling multiple technology projects, the challenge is often not one individual DPIA but creating a process that works repeatedly.
We can help design or review your:
We can also train the teams responsible for applying the process.
The objective is a proportionate system that identifies material privacy risks early without turning privacy review into an unnecessary bottleneck for every technology initiative.
Our objective is to find proportionate ways of reducing and managing risk – but not every risk can or should be engineered away through launch conditions.
Where high residual risk cannot be sufficiently mitigated, the GDPR may require prior consultation with the competent supervisory authority.
We have experience supporting clients in interactions with supervisory authorities concerning DPIAs, both proactively and where an assessment becomes relevant in a regulatory inquiry or enforcement matter.
Identifying those situations early gives management more options and a stronger basis for its decisions.
Tell us what you are building, buying or changing and what decision you need to make.
We determine whether the appropriate starting point is a focused Privacy Snapshot, a targeted DPIA/addendum or a more comprehensive DPIA.
We identify the relevant stakeholders and materials and agree on the questions the assessment needs to answer.
We then propose a clear scope, deliverables and commercial model before substantive work begins.
We work with the relevant members of your product, technology, security, commercial and legal teams to understand the processing, identify material risks and develop proportionate safeguards.
We document the assessment and residual risk and help determine the appropriate route forward – including, where appropriate, conditions for a controlled launch.
Where useful, we help establish monitoring, reassessment triggers and measurable conditions for further rollout or scale-up.
The appropriate scope depends on the technology, risk and purpose of the assessment.
For defined projects, we can often work on a fixed-fee basis with agreed deliverables and assumptions.
For organisations with recurring assessments, we can establish a scalable ongoing support model.
The earlier privacy questions are identified, the more options your team normally has.
If launch is already approaching, we can help determine what genuinely needs to be resolved before go-live and whether remaining uncertainty can be managed through a narrower initial release, additional safeguards and structured post-launch monitoring.
The goal is not compliance at the expense of innovation. It is to help you build, launch and scale on a defensible foundation.
