# AEPD publishes GDPR Risk Assessment

- Type: News
- Source: AEPD
- Date: 2022-10-11
- Original: https://evalua-riesgo.aepd.es/index_en.html#entry-1032
- Canonical: https://overview.legal/posts/6259
- Topics: Marketing, DPIA, Privacy Impact Assessment, Monitoring, Employees, Profiling, Automated Decision-Making, Criminal Data, Lawful Basis, Integrity and Confidentiality Principle

## Summary

> GDPR RISK ASSESSMENT is intended to assist controllers and processors to identify the risk factors for the rights and freedoms of data subjects whose data are present in the processing, to make an initial assessment of the intrinsic risk, including the need to perform a DPIA, and to estimate the residual risk if measures and safeguards are used to mitigate the specific risk factors.

## Full text

[![Web AEPD](res/aepd-logo-2_1.png)](https://www.aepd.es "Web AEPD") 

# GDPR Risk Assessment

[Castellano](index.html) | [English](index%5Fen.html) 

* Purposes
* Types of data
* Scope
* Data subjects
* Techniques
* Collection
* Effects
* Controller
* Communications
* Other
* Security
* Results

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### Operations related to the purposes of processing

Risk factors arising from the stated purpose of the processing and other purposes linked to the main purpose.

 Profiling 

Creating profiles 

Use of profiles 

Classification of individuals 

Targeting of products/services to individuals or groups 

Behavioral analysis (evaluation and rating of emotions, moods, habits, preferences, etc.) 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Assessment of subjects 

Valuation 

Scoring 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Prediction 

Inference of new personal data 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Employee control 

Employee evaluation 

Job observation 

Workplace monitoring 

Workplace image recording 

Workplace audio recording 

Geolocation of workers en route 

Monitoring 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Internet access control 

Analysis or evaluation of Internet usage time 

Internet browsing activity 

alarms on browsing to specific Internet sites 

alarms on browsing to specific Internet contents 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Observance 

Image surveillance 

Sound surveillance 

Communication monitoring 

Monitoring of heat or other emissions 

Transmission monitoring 

Internet monitoring 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Monitoring 

IoT management 

Image monitoring 

Sound monitoring 

Communication monitoring 

Control of heat or other emissions 

Transmission control 

Internet control 

Geolocation control 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Supervision 

Control 

Image analysis 

Sound analysis 

Communications analysis 

Analysis of heat or other emissions 

Transmission analysis 

Internet analysis 

Geolocation analysis 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Contact tracing 

Apply 

Mitigation

Not Mitigated Mitigated 

 Physical access control 

Access control to work premises 

Access control to commercial premises 

Access control to events 

Access control to sports facilities 

Access control to buildings (public/private) 

Geolocation 

Movement profiling 

Determination of usual places 

Determination of frequent places of access 

Personal data inferred from geolocation 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Location 

Apply 

Mitigation

Not Mitigated Mitigated 

 Univocal identification 

Apply 

Mitigation

Not Mitigated Mitigated 

 Automated decisions without human intervention 

Apply 

Mitigation

Not Mitigated Mitigated 

 Automated processing for decision support 

DSS 

Business intelligence that exceeds purely statistical data 

AI 

Data mining 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Deciding on, or avoiding the exercise of fundamental rights 

Impedes or hinders: Right to equality 

Right to non-discrimination 

Right to life and physical integrity 

Right to religious freedom 

Right to personal freedom 

Right to privacy 

Right to self-image 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Deciding on the data subject's control of his or her personal data 

Prevent or hinder: Right of access 

Right of rectification 

Right of opposition 

Right of erasure 

Right to limitation of processing 

The right not to be subject to automated decisions 

Right to portability 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Deciding on access to a service 

Apply 

Mitigation

Not Mitigated Mitigated 

 Deciding on the execution or performance of a contract 

Apply 

Mitigation

Not Mitigated Mitigated 

 Deciding on access to financial services 

Apply 

Mitigation

Not Mitigated Mitigated 

 Legal effects on persons 

Apply 

Mitigation

Not Mitigated Mitigated 

 Genetically based disease/health assessment and/or prediction 

Apply 

Mitigation

Not Mitigated Mitigated 

 Preservation for archival purposes 

Apply 

Mitigation

Not Mitigated Mitigated 

### Types of data used

Risk factors related to the scope of the processing which arise from the data collected, processed or inferred in the processing.

 Personal documents 

Personal mail 

Personal letters 

Diaries 

E-reader notes 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Information from vital logger applications 

Apply 

Mitigation

Not Mitigated Mitigated 

 Personal aspects 

People or groups with whom you relate 

Temperament 

Character 

Intelligence 

Social roles 

Ability to adapt 

Risk tolerance 

Audiovisual content tastes/preferences 

Habits 

Personal interests 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Consumption preferences, tastes, habits (no special categories) 

Consumption preferences 

Consumption habits 

Preferences for audiovisual content in different media 

Leisure preferences 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Job performance 

Access control 

Image recording 

Audio recording 

Worker evaluation 

Equipment monitoring 

Performance inference 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Economic situation 

Personal income 

Monthly income 

Assets (movable/immovable property) 

Employment status 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Financial statement 

Financial solvency 

Debt capacity. 

Level of debt (personal loans, mortgages) 

Solvency lists 

Debts 

Assets 

Liabilities 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Means of payment 

Credit cards 

Information on access to virtual currency services 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Behavioural data 

Apply 

Mitigation

Not Mitigated Mitigated 

 Location data 

Travel log 

Record of usual places 

Record of routines based on location 

Record of usual places 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Very personal data 

Very personal data not included in previous classifications 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Health data 

Medical records 

Health reports 

Health-related sick leave reports 

Medical prescriptions 

related to physical health 

related to mental health 

related to health care service delivery 

iHealth Apps 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Biometric data 

Fingerprint 

Facial features 

Iris 

Palm veins 

Voice 

Ear 

Gestures 

Gait 

Body descriptors of any kind 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Genetic data 

Apply 

Mitigation

Not Mitigated Mitigated 

 Special categories of data or data that allows to infer special categories of data 

Ethnic origin 

Racial origin 

Political opinions 

Religious convictions 

Philosophical convictions 

Trade union membership 

Health-related data 

Data concerning sexual life/orientation 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Special categories of pseudonymised data 

Apply 

Mitigation

Not Mitigated Mitigated 

 Personal data relating to convictions and criminal (or administrative) offences 

Apply 

Mitigation

Not Mitigated Mitigated 

 Metadata 

Electronic communications traffic data 

Identification of sender and/or receiver in communications 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Unique identifiers 

IP 

MAC 

IMSI or IMEI 

Device ID 

Phone N. 

DNI, NIE, Passport No. or equivalent 

Social security number 

Vehicle registration number 

Credit card number 

UID 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Electronic communications data and metadata 

E-mails 

Instant messages 

Phone calls 

Video calls 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Web browsing data 

Logs of: Visited pages 

Activity time 

Visits 

Connections 

Mouse activity 

Browser/device used 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

### Extent and scope of data processing

Risk factors related to the scope of the processing after the number of subjects concerned, the diversity of data or aspects processed, the duration in time, the volume of data, the geographical extent, the completeness on the individual, the frequency of collection, etc.

 Systematic 

 Occurs according to a system 

Is pre-established, organized or methodical 

Occurs as part of an overall data collection plan 

Carried out as part of a strategy 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Comprehensive on people 

A wide variety of different elements are collected and processed 

Multiple areas of your life 

Different aspects of personality are covered 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Involves a large number of data subjects 

The number of affected stakeholders is high in absolute numbers. 

The number of affected data subjects is high in relation to the corresponding population. 

The number of data subjects is relevant in relation to the geographic extension. 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 The volume of data processed is very high 

Apply 

Mitigation

Not Mitigated Mitigated 

 Long processing duration 

The permanence of the processing is high 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Large geographic scope of processing activity 

Regional, national or supranational level 

Other 

Enter risk factor 

Mitigation

Not Mitigated Mitigated 

 Large-scale processi

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Generated by overview.legal · https://overview.legal/posts/6259 · 2026-08-22
