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Your AI tool needs a DPIA: a GDPR Article 35 write-up sheet for small businesses (the four required parts, risk scores, sign-off and when to ask the authority)

Updated 24 Oct 2026 · Disclosure: the EURO AI Register mentioned below is an Unadhi product with a free edition. This guide is for information only, not legal advice.

What you get: a finished DPIA write-up sheet: one row per AI tool that screened in, one column for each of the four parts Article 35(7) GDPR requires, likelihood and severity scores before and after your measures, columns for DPO advice, people's views and the EU AI Act inputs, a decision formula that tells you when to consult your data protection authority (Article 36), a sign-off and review date, and two made-up example rows.

Short answer: if your DPIA screening says an AI tool needs a DPIA, you must write it before you start using the tool. It must at least describe the processing and purposes, explain why it is necessary and proportionate, assess the risks to people, and list the measures that address those risks. If a high risk remains that your own measures cannot reduce, you must consult your data protection authority before you start.

Step 1: before you write

Step 2: the DPIA write-up sheet (one row per AI tool, risk lines underneath)

ColumnWhat to writeSource
A. Processing and AI tool[what you do] · [AI tool or supplier] · one row can cover a set of similar processing operations with similar high risksArt. 35(1)
B. Screening resultDate and reason the tool screened in (for example two or more criteria on the DPIA screening sheet, or one of the three Article 35(3) cases). The DPIA must be done before the processing startsArt. 35(1), 35(3)
C. Description and purposesWhat data, about whom, from where, which AI features, who receives it, how long it is kept, and the purpose. If you rely on legitimate interests, name the interestArt. 35(7)(a)
D. Necessity and proportionalityWhy this processing is needed for the purpose; a less intrusive option you considered and why you did or did not take it; which fields you switched off; retentionArt. 35(7)(b)
E. Risks to peopleOne line per risk: what could go wrong for the person (wrong AI output used against them, data reused for training, staff monitored, leak of a transcript). Rate likelihood L and severity S from 1 to 3 (your own working scale)Art. 35(7)(c); Recitals 84, 90
F. Score before measures=E_L*E_S per risk line, for example =F2*G2 if L and S sit in their own columnsRecital 90 (likelihood and severity)
G. MeasuresSafeguards, security measures and ways to show compliance, one per risk: switch off training on your data, shorter retention, human review before decisions, access limits, notice wordingArt. 35(7)(d)
H. Score after measuresRe-rate L and S with the measures in place; same formulaArt. 35(7)(d); Art. 36(1)
I. DPO adviceIf you have designated a DPO: date and summary of the advice, and whether you followed it. If not designated: write "none designated"Art. 35(2)
J. Views of people or their representativesWhere appropriate: staff or works council asked, customer feedback, or why you did not askArt. 35(9)
K. AI Act inputsHigh-risk AI systems: the provider's instructions for use read and used (Art. 26(9) AI Act). Fundamental rights impact assessment needed? Note where the DPIA already covers it (Art. 27(4) AI Act). Approved code of conduct followed (Art. 35(8) GDPR)AI Act Art. 26(9), 27(4); GDPR Art. 35(8)
L. Decision=IF(MAX(H2:H9)>=$Z$1,"Consult authority before start (Art. 36)",IF(MAX(H2:H9)>=$Z$2,"Start only with listed measures","Start")) with your own thresholds in Z1 and Z2 (for example 6 and 4 on the 1 to 9 scale). These numbers are a working aid, not a legal ruleArt. 36(1); Recital 84
M. Sign-offName of the role that signs, date, and where the DPIA file is storedArt. 5(2), 24(1)
N. ReviewChange that triggers a review (new AI feature, new data, new supplier, new purpose) and next planned review date, for example =EDATE(M2,12) as your own routineArt. 35(11)

Keep the risk lines (E to H) on rows 2 to 9 under each tool, or on a second tab with the tool name in the first column. Sort by column L so "Consult authority before start" comes first. The 1 to 3 scales and the thresholds are your own working numbers; the GDPR asks you to assess likelihood and severity (Recital 90) but does not set a scale.

Step 3: if column L says "Consult authority before start"

Two example rows (made-up businesses, for illustration only)

Do this week

This sheet is a working aid, not a legal opinion or proof of compliance. References are to Regulation (EU) 2016/679 (Articles 35 and 36 and Recitals 84 and 90, as published on gdpr-info.eu), Regulation (EU) 2024/1689 (AI Act Articles 26(9) and 27(4), as published on artificialintelligenceact.eu) and the Article 29 Working Party Guidelines on Data Protection Impact Assessment (wp248rev.01). Your national data protection authority publishes its own list of processing that needs a DPIA (Art. 35(4)); check it. Example rows are made up for illustration and do not describe any real business or supplier. Checked on 24 October 2026. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

Clients who start using AI for recruitment, call recording or customer scoring often find out about the DPIA only when a customer or employee asks for it. Hand them the screening sheet and this write-up sheet together with the client AI inventory, so each tool has a dated, signed row. Stay inside your professional rules and refer legal questions on.

Keep the DPIA next to your AI register

The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. List each AI tool once and attach its DPIA row and sign-off as an evidence record.

When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.

Partner programme opening soon

Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

Free start: list your AI tools in the EURO AI Register free edition, then add this sheet. Related: DPIA screening sheet · Article 22 automated decision sheet · do we need a DPO? · Article 9 health data sheet

Sources

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