Announcing the release of PIA Template v2.0! Learn more

The Sigma PIA Template: Maximum Rizz for Privacy Pros

By Meaghan McCluskey

It’s finally here! The PIA template with mad rizz1! The Privacy Pro has released version 2.0 of our Privacy Impact Assessment template and it is a total W, no cap. It’s basic in a good way: an Excel spreadsheet with guidance and logic built in. It slaps because the OGs don’t have to remember another login.

Three young professionals in an office. The main character has blue hair and a bright pink sweatshirt.

You may believe that a PIA template should cover all applicable privacy laws, and I am here to disabuse you of that notion.

When I led the research team at TrustArc, I would frequently hear questions like “well, does your PIA cover China?” The short answer is no, and it doesn’t need to.

Let’s be clear about what a PIA is, and is not. A PIA is an artifact of a conversation to:

  • Understand the business context
  • Document what is happening with data 
  • Identify the associated privacy risks
  • Implement controls and safeguards

A PIA is not a compliance assessment; it is not going to tell you that you are compliant with China’s PIPL, the CCPA, Quebec Law 25, and the myriad other privacy laws. Each of those have their own nuances that need to be addressed. Insert cry emoji. 

Instead, our PIA focuses on demonstrating accountability, because if you know Lauren and me, you know we love accountability almost as much as we love frameworks. The end goal is that you can confidently make ten statements that demonstrate accountability, supported by evidence:

  1. We are accountable for privacy and data.
  2. We only process data for specified, lawful purposes.
  3. We take extra care when processing data may result in a higher risk to people.
  4. We know what we’re doing with people’s data.
  5. People know what we’re doing with their data.
  6. People can exercise their privacy rights.
  7. We protect data from unauthorized access, use or disclosure.
  8. We are accountable for data, even when it is processed by someone else.
  9. We don’t keep data we don’t need.
  10. We address the specific compliance requirements that apply to certain activities. 

Our PIA only has 15 questions, none of which are about privacy

It seems counterintuitive to have so few questions given the complexity of privacy laws, but it works. We’re not delulu, we spent years narrowing the list to things that actually matter. You can be a good partner to business and keep your main character energy. 

The questions are framed in a way that the business can answer without any privacy expertise, and are asked in plain language. We don’t use privacy jargon (or gen-Z slang): “legal grounds for processing”, “minimum necessary for the purposes of processing”, “transparency” – none of these terms are found in the questions. Instead we ask about how data is collected and used, and what data, using multiple choice questions. There’s no need for the business team to try and interpret the definition of “profiling” under Colorado’s Privacy Act or whether a particular data element is “identifiable.”

Don’t be extra (not everything needs your immediate attention)

Our PIA template has a built-in threshold assessment that has been refined to provide a more nuanced understanding of high-risk scenarios. Risk needs context. For example, just because a project includes sensitive data does not necessarily mean that the project poses a high risk.  Our contextual approach helps you focus on the important things, rather than doing a PIA for every single initiative involving data.

By triaging the need for PIAs and reducing them to 15 questions, we have already gone a long way towards easing some of the pain regarding PIAs. But version 2.0 of the PIA has been updated based on how our clients have used this tool IRL to collaborate between privacy and business teams.

The workflow built into the template makes it clear AF which team is responsible for which questions and requirements. And those aspects of processing that indicate higher risk are clearly flagged so that the business team knows what to expect. They understand that if their project involves one of those aspects, additional scrutiny and time may be required. No sus vibes involved.

Want to level up this convo?

Peep the details on our PIA page and consider signing up for our webinar, How To Be a Business-savvy Privacy Pro, where we will walk through a case study using this template or a PIA Workshop for more hands-on practice where you can try the template for yourself!

  1. Warning: I have been trying to learn the Gen-Z slang so that I can talk to the young folk. It’s not going well. ↩︎


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