DPO Approval Workflows
Complete guide to managing Data Protection Officer approval workflows for DPIAs and high-risk processing activities
📑 Quick Navigation
What is DPO Approval?
Under GDPR Article 35(2), organizations must consult their Data Protection Officer (DPO) when carrying out Data Protection Impact Assessments (DPIAs) for high-risk processing activities.
📜 GDPR Article 35(2) - Legal Requirement
"The controller shall seek the advice of the data protection officer, where designated, when carrying out a data protection impact assessment."
Penalty for Non-Compliance: Up to €10 million or 2% of worldwide annual turnover (whichever is higher)
When is DPO Approval Required?
- Mandatory DPIA triggers (Article 35(3)):
- Systematic and extensive profiling with legal effects
- Large-scale processing of special category data (health, biometric, etc.)
- Systematic monitoring of publicly accessible areas (e.g., CCTV)
- New AI systems or algorithms (EU AI Act Article 27)
- Cross-border data transfers to non-adequate countries
- Significant changes to existing processing activities
The DPO's Role
As your organization's DPO (or designated approver), you are responsible for:
Assess whether the DPIA adequately identifies risks and proposes mitigation measures
Provide expert guidance on compliance requirements and best practices
Identify high/residual risks that require supervisory authority consultation
Create audit trail showing DPO consultation occurred (Article 35(2) evidence)
Accessing Your Approval Queue
Your approval queue is accessible from multiple locations based on your subscription tier:
🎯 Navigation Paths
Dashboard → ApprovalsURL: /dashboard/professional/approvals
Dashboard → ApprovalsURL: /dashboard/enterprise/approvals
Dashboard → ApprovalsURL: /dashboard/enterprise-plus/approvals
Permission Requirements
Access Control
You must have the "DPO" role assigned to your user account to access approval workflows.
How to check: Go to Team Settings → View your role. Contact your Organization Admin to assign the DPO role if you don't have it.
What You'll See
Your approval queue displays:
- Pending Reviews: DPIAs submitted by your team awaiting your approval
- Risk Level: Color-coded risk assessment (High: Red, Medium: Orange, Low: Green)
- Submission Date: When the DPIA was submitted for review
- Processing Activity: Name/description of the data processing
- Submitter: Team member who created the DPIA
💡 Pro Tip: Email Notifications
Enable "DPIA Submission Notifications" in your settings to receive emails when new DPIAs are submitted for your review. This ensures you never miss a high-priority approval request.
How to Review a DPIA
Follow this systematic review checklist to ensure comprehensive GDPR compliance:
Step 1: Open the DPIA
- Navigate to your Approvals queue
- Click on the DPIA title to open the full assessment
- Review the automatically generated summary at the top (risk level, data categories, etc.)
Step 2: Verify Completeness
Check that all required fields are filled out:
| Section | Required Fields | What to Look For |
|---|---|---|
| Processing Details | Purpose, legal basis, data categories | Clear, specific descriptions (not vague) |
| Necessity Test | Justification for processing | Proportionality assessment present |
| Risk Assessment | Identified risks + likelihood/impact | Realistic risk scores (not all "low") |
| Mitigation Measures | Technical + organizational safeguards | Specific controls (not generic statements) |
| Residual Risk | Post-mitigation risk level | Acceptable within risk appetite |
Step 3: Red Flags to Watch For
- • Special category data (health, biometric) without adequate safeguards
- • No encryption for data in transit or at rest
- • Third-party processors in non-adequate countries (e.g., US without SCCs/DPF)
- • Automated decision-making with legal/significant effects
- • No data retention policy or excessive retention periods
- • Vague purpose statements ("business operations")
- • Missing legal basis for processing
- • No clear data subject rights procedures (access, deletion, etc.)
- • Insufficient access controls (everyone has admin access)
- • No incident response plan
Step 4: Consult Documentation
Review any attached evidence:
- Data flow diagrams
- Vendor DPA (Data Processing Agreement)
- Security certifications (ISO 27001, SOC 2)
- Privacy notices provided to data subjects
- Previous audit findings or certifications
Approval Actions
After reviewing the DPIA, you have three options:
✅ Approve
Use when the DPIA adequately addresses all risks and complies with GDPRGDPR requirements.
- • DPIA status changes to "APPROVED"
- • Processing activity can proceed
- • Approval timestamp recorded in audit log
- • Submitter receives email notification
- • DPIA included in compliance package export
🔄 Request Revision
Use when the DPIA has issues that need correction before approval (e.g., missing information, inadequate risk assessment).
- • DPIA status changes to "NEEDS_REVISION"
- • DPIA returned to submitter for updates
- • Your feedback comment sent to submitter
- • Submitter re-submits for approval after fixes
- • You receive notification when resubmitted
❌ Reject
Use when risks are unacceptable and cannot be mitigated, or when the processing violates GDPR principles (e.g., no legitimate legal basis).
- • DPIA status changes to "REJECTED"
- • Processing activity MUST NOT proceed
- • Rejection recorded in audit log (critical for proving due diligence)
- • Submitter receives rejection notification
- • May require supervisory authority consultation (Article 36)
⏱️ Response Time SLA
Best Practice: Review and respond to DPIAs within 5 business days of submission. For high-risk processing (e.g., AI systems, health data), aim for 2 business days to avoid delaying critical projects.
Audit Trail & Export
All DPO approval activities are automatically logged to demonstrate GDPR Article 35(2) compliance.
What's Recorded
- Timestamp: Exact date/time of approval/rejection
- DPO Identity: Your name andEmail
- Action Taken: Approved, Rejected, or Requested Revision
- Comments: Your feedback/reasoning
- DPIA Details: Processing activity name, risk level, data categories
Exporting Audit Logs
To export your approval history:
- Navigate to Dashboard → Audit
- Filter by Resource:
DPIA_APPROVAL - Filter by Action:
APPROVE,REJECT, orREQUEST_REVISION - Click "Export CSV"
📦 Included in Compliance Package Export
All DPO approvals are automatically included in the 24-file compliance package export. This provides auditors with evidence that:
- • Article 35(2) consultation occurred
- • DPO advice was documented
- • High-risk processing was properly reviewed
- • Approval/rejection decisions were evidence-based
❓ Frequently Asked Questions
Q: What if I disagree with a DPIA's risk assessment?
A: Request revision and provide specific feedback. For example: "Risk level should be 'High' not 'Medium' because this involves automated decision-making with legal effects (Article 35(3)(a)). Add human review in the loop."
Q: Can I delegate DPO approvals to someone else?
A: Yes, but only to someone with equivalent GDPR expertise. Assign the "DPO" role to them from Team Settings. Remember: you remain accountable for ensuring consultations occur (Article 38).
Q: What if processing has already started without a DPIA?
A: This is a GDPR violation (Article 35(1)). Immediately: (1) Request DPIA creation from the project team, (2) Document the violation in your incident log, (3) Consider suspending processing until DPIA is approved, (4) Escalate to management/legal if processing continues.
Q: How long should I keep approved DPIAs?
A: Minimum: Duration of the processing activity + 3 years (for audit purposes). Best practice: 7 years (aligns with SOC 2 / ISO 27001 requirements). All DPIAs are stored indefinitely in our system unless manually deleted.
Q: Do I need to review DPIAs annually even if nothing changed?
A: Yes, best practice is annual review + re-approval (or when significant changes occur). This ensures risks remain acceptable as technology/threats evolve. Set a recurring calendar reminder for each approved DPIA.
Q: What happens if I reject a DPIA but management wants to proceed anyway?
A: Document this conflict immediately. Under Article 38(3), you must be able to perform your tasks independently. If management overrules your rejection: (1) Send formal written objection, (2) Escalate to the board/CEO, (3) Consider whether supervisory authority consultation (Art. 36) is required. In extreme cases, this may be grounds for resignation and whistleblowing.