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When is a data protection impact assessment (DPIA) mandatory when processing police data (Wpg) within municipalities?

October 28, 2025

Question & Answer

ANSWER

A DPIA is required as soon as a processing of police data is likely to present a high risk to the rights and freedoms of data subjects. This is similar to the AVG. Consider, for example, processing that involves: (i) large-scale targeting, (ii) profiling, (iii) or camera surveillance. Do not be put off by the wording in the AVG that a DPIA is "particularly required" in the case of criminal data: also under the Wpg, the starting point is the same. As soon as there is an increased risk, a DPIA is required.