Most HR teams hear “DPIA” and think it’s a legal or security exercise. Under India’s DPDP Act, a DPIA (Data Protection Impact Assessment) is simply a structured way to spot risk before data harm happens – especially in HR, where sensitive personal data is routine.
This guide shows how HR can run a simple, practical DPIA without lawyers or complex frameworks.
What Is a DPIA (in HR terms)?
A DPIA is a short assessment to answer one question:
Could this HR process harm employees’ personal data – and if yes, how do we reduce that risk?
It focuses on:
- What data you collect
- Why you collect it
- Who accesses it
- How long you keep it
- What could go wrong
When Should HR Run a DPIA?
Run a DPIA when an HR workflow:
- Handles large volumes of employee data
- Involves sensitive personal data
- Uses new tools, AI or automation
- Shares data with external vendors
- Impacts employees at scale
Common HR workflows needing DPIA:
- Background verification
- Recruitment & ATS systems
- Attendance, productivity or monitoring tools
- Pulse surveys & engagement platforms
- Exit & offboarding processes
Step 1: Map the HR Workflow (10 Minutes)
Document the process in simple terms:
- What is the workflow?
- Whose data is involved? (candidates, employees, ex-employees)
- What data fields are collected?
- Which systems or vendors are used?
- Who can access the data?
If you can’t explain the workflow clearly, you can’t protect the data.
Step 2: Identify Data Risks
Ask these four questions:
- Is any data excessive for the stated purpose?
- Is sensitive data shared unnecessarily?
- Are access controls too broad?
- Is data stored longer than needed?
Typical HR risks uncovered:
- Old resumes kept indefinitely
- ID proofs reused across processes
- Vendor access not time-bound
- Excel exports shared over email
Step 3: Assess Impact if Things Go Wrong
For each risk, ask:
- What happens if this data is leaked, misused or accessed wrongly?
- Could it cause:
- Financial harm?
- Reputation damage?
- Emotional distress?
- Legal exposure?
- Financial harm?
You don’t need numbers – just Low / Medium / High impact.
Step 4: Apply Risk Reduction Controls
Match risks with simple fixes:
- Collect only minimum required data
- Mask or redact sensitive fields
- Restrict access by role, not convenience
- Set clear retention & deletion timelines
- Ensure vendors follow DPDP-aligned controls
If a risk can’t be reduced meaningfully → rethink the workflow.
Step 5: Record & Review
Your DPIA doesn’t need to be fancy.
A simple record should include:
- Workflow name
- Risks identified
- Controls applied
- Owner (HR / IT / Legal)
- Review date
Revisit when:
- The workflow changes
- A new vendor is added
- A data incident occurs
What a “Good” HR DPIA Looks Like
✔ Short
✔ Practical
✔ Action-oriented
✔ Repeatable across workflows
Not a legal thesis. Not a security audit.
Why DPIAs Matter for HR Under DPDP
Under DPDP, HR teams are no longer just process owners – they are data risk owners.
A simple DPIA helps HR:
- Prevent data breaches
- Reduce compliance exposure
- Ask better questions of vendors
- Build trust with employees
- Stay audit-ready without panic
Practical Playbook: DPIA Tools HR Can Use
This section provides ready-to-use tools HR teams can apply immediately across workflows.
⬇️
1-Page DPIA Template for HR (DPDP-Ready)
Use this template whenever HR introduces or modifies a workflow involving personal data.
A. Workflow Overview
- Workflow name:
- HR function (Hiring / Payroll / Engagement / Exit / Others):
- Data owner (HR SPOC):
- Vendors involved (if any):
B. Categories of Personal Data
☐ Identity data (name, phone, email)
☐ Government IDs (Aadhaar, PAN, passport)
☐ Financial data (salary, bank details)
☐ Health / medical data
☐ Background verification data
☐ Performance / behavioural data
C. Purpose & Necessity
- Why is this data required?
- Is every data element necessary for this purpose?
- Can the purpose be achieved with less data?
D. Risk Identification
☐ Unauthorised access
☐ Excessive data retention
☐ Vendor misuse or overreach
☐ Accidental disclosure
☐ Failure to honour data principal rights
E. Safeguards in Place
☐ Role-based access controls
☐ Encryption (at rest / in transit)
☐ Defined retention & deletion timelines
☐ Vendor DPA and controls
☐ Logs and monitoring
F. Residual Risk Assessment
- Risk level: Low / Medium / High
- Justification:
G. Action Items
- Gaps identified:
- Owner:
- Timeline:
Approvals
- HR Head:
- Legal / Compliance:
- Date:
DPIA as an Internal HR Checklist / SOP
Treat DPIA as a standard operating process, not a one-time compliance exercise.
Step 1: Identify the Trigger
Run a DPIA if any of the following apply:
☐ New HR tool or vendor
☐ New type of employee data
☐ Processing at scale
☐ Sensitive personal data involved
☐ Automation or workflow redesign
If any one box is ticked, initiate DPIA.
Step 2: Map the Data Flow
☐ What data is collected?
☐ From whom?
☐ Where is it stored?
☐ Who can access it?
☐ Which vendors process it?
Step 3: Assess Risk
☐ What can go wrong?
☐ Who may be impacted?
☐ What is the likelihood of harm?
Step 4: Apply Safeguards
☐ Minimise data collection
☐ Restrict access
☐ Define retention and deletion
☐ Strengthen vendor controls
Step 5: Document & Sign Off
☐ DPIA documented
☐ Risks mitigated or accepted
☐ Internal approvals completed
No documentation = no defensible compliance.
DPIA Triggers Across the Employee Lifecycle
Use this map to proactively spot where DPIAs are most relevant.
Hiring & Recruitment
- Resume databases
- Interview recordings
- Psychometric and assessment tools
- Background verification
Trigger: Third-party + sensitive data
Onboarding
- Aadhaar / PAN collection
- Bank and payroll setup
- Insurance enrolment
Trigger: Identity and financial data
Employment Lifecycle
- HRMS and attendance systems
- Performance reviews
- Engagement and survey tools
Trigger: Behavioural and profiling data
Benefits & Wellness
- Health insurance
- Wellness and mental health platforms
Trigger: Sensitive personal data
Exit & Offboarding
- Access revocation
- Data retention decisions
Trigger: Retention and deletion risk
Post-Employment
- Alumni databases
- Legal records and references
Trigger: Purpose limitation and excess retention
Bottom Line
You don’t need perfection. You need visibility, intent and basic controls.
If HR workflows touch personal data (they do), DPIAs are no longer optional – they’re operational hygiene.
