According to Article 35 of the GDPR, a Data Protection Impact Assessment (DPIA) is required when the processing of data is likely to result in a high risk to the rights and freedoms of natural persons, especially when using new technologies. A DPIA is supposed to show the characteristics of the processing, the risks and the measures adopted to mitigate them. The GDPR also provides some examples of processing operations that require a DPIA, such as:
a systematic and extensive evaluation of personal aspects based on automated processing, including profiling, and on which decisions are based that produce legal or significant effects on the data subject;
processing on a large scale of special categories of data or data relating to criminal convictions and offences; or
a systematic monitoring of a publicly accessible area on a large scale.
Among the answer choices, only option C falls under the first example, as it involves a systematic and extensive evaluation of personal aspects based on location data and data from third-party sources, which could be used for profiling and matching purposes. This could have significant effects on the data subjects’ privacy, personal relationships and reputation. Therefore, a DPIA would be required for this processing operation.
Option A does not necessarily involve a systematic and extensive evaluation of personal aspects, nor does it produce legal or significant effects on the data subject. It could be considered a legitimate interest of the company to offer more personalized service, as long as it respects the principles of data minimization, purpose limitation and transparency.
Option B does not involve a decision based on the processing, nor does it produce legal or significant effects on the data subject. It could be considered a form of direct marketing, which is subject to specific rules under the GDPR and the ePrivacy Directive.
Option D does not involve personal data relating to natural persons, but rather to delivery trucks. Therefore, it does not pose a high risk to the rights and freedoms of natural persons.
References:
[Reference: http://webcache.googleusercontent.com/search?q=cache:aQkU17eX9sQJ:https:// www.shlegal.com/insights/article-29-data-protection-working-party-gdpr-guidelines-on-data-protection-impact- assessments&client=firefox-b-e&hl=en&gl=pk&strip=1&vwsrc=0, ]
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