Privacy impact assessment

A two-stage PIA, with a ten-minute threshold check to decide whether you need one and a full assessment structured around the information privacy principles.

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Licence
CC BY 4.0, free to adapt
Sources
6 cited

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Remove the guidance notes in square brackets before you publish.

How to use this

A privacy impact assessment (PIA) is a structured way to find privacy risks in a project before they’re built in, when they’re cheap to fix. The Privacy Commissioner expects PIAs for new AI tools, biometric processing and significant changes in how you handle personal information, and its Poupou Matatapu treats assessing risk as one of the ten pou.

Consultancies often charge thousands for a PIA. Much of that cost is understanding the project, which you already do. Use this template yourself; bring in a specialist to review the result if the project is high-risk.

Do the threshold check first. If every answer is “no”, record that and stop.

Privacy impact assessment

Project: [name] Owner: [name, role] Assessed by: [name] Date: [date] Version: [1.0]

Part A: Threshold check

Answer yes or no. Any “yes” means you should complete Part B.

# Question Yes / No
A1 Will we collect new personal information, or collect it in a new way?
A2 Will we use existing personal information for a new purpose?
A3 Will we share personal information with a new organisation, or send it overseas?
A4 Does it involve sensitive information (health, children, financial, ethnicity, justice, location)?
A5 Does it involve AI, automated decisions, profiling or data matching?
A6 Does it involve biometric processing (face, fingerprint, voice)?
A7 Does it involve monitoring or tracking people (cameras, location, device or activity monitoring)?
A8 Will we collect information about people from someone other than them?
A9 Could people reasonably be surprised or upset by it?
A10 Will a new supplier hold or process personal information for us?

Outcome: [No PIA needed, reason recorded / Full PIA required]

Part B: Full assessment

B1. Description

What is the project, what problem does it solve, and when will it go live? Who are the people whose information is involved (customers, staff, children, the public)?

B2. Information flows

Describe or draw how information moves, covering what’s collected, from whom, where it’s stored, who uses it, who it’s shared with, and when it’s deleted. A simple table works:

Information Source Stored in Used by Shared with Retention

B3. Assessment against the privacy principles

Principle Question Finding Risk (L/M/H)
IPP 1 Purpose Is every item of information necessary for the purpose? What could we not collect?
IPP 2 Source Are we collecting from the person? If not, what’s the basis?
IPP 3 Notice (direct) How will people be told the IPP 3 matters?
IPP 3A Notice (indirect) For indirect collection, how will people be told, or which exception applies and what’s our evidence?
IPP 4 Manner Is collection fair and not unreasonably intrusive? Any children or young people?
IPP 5 Security What safeguards fit the sensitivity? Access control, MFA, encryption, logging, supplier security?
IPP 6 and 7 Access and correction Can we find, provide and correct a person’s information within 20 working days? Including AI outputs?
IPP 8 Accuracy How will we check accuracy before acting on it? Is there human review?
IPP 9 Retention How long is it kept, and how will deletion happen in practice?
IPP 10 Use Is every use consistent with the purpose people were told?
IPP 11 Disclosure What’s the basis for each disclosure?
IPP 12 Overseas Does information go overseas? Held for us (s 11), or disclosed? What safeguards?
IPP 13 Unique identifiers Are we assigning or reusing identifiers?

B4. Wider risks

  • Collective and group harm: could this harm a group or community, including Māori communities, even where no individual is identified?
  • Fairness and bias: could it work less well, or more harshly, for some groups?
  • Function creep: what could this be used for later, and what stops that?
  • Biometrics: if A6 was yes, complete the biometric proportionality worksheet.
  • Codes of practice: does a code (health, credit, telecommunications, biometrics) apply?

B5. Consultation

Who did you consult? Affected people, staff, iwi or Māori partners, your privacy officer, the supplier, specialists? What did they say?

B6. Risks and actions

Risk Likelihood Impact Action Owner Due

B7. Sign-off

Recommendation: [proceed / proceed with actions / don’t proceed]

Residual risk accepted by: [name, role, date]

Review date: [when the PIA will be revisited, for example 6 months after go-live or on any significant change]

Sources

  1. Privacy Impact AssessmentsOffice of the Privacy Commissioner. Checked 19 October 2026.
  2. Generative artificial intelligence: OPC expectationsOffice of the Privacy Commissioner. Checked 19 October 2026.
  3. Biometric Processing Privacy Code 2025Office of the Privacy Commissioner. Checked 19 October 2026.
  4. Privacy Act 2020, s 22 (the information privacy principles)NZLII. Checked 19 October 2026.
  5. IPP3A: notification requirements for indirect collection of personal informationOffice of the Privacy Commissioner. Checked 19 October 2026.
  6. Poupou Matatapu: doing privacy wellOffice of the Privacy Commissioner. Checked 19 October 2026.

Something wrong or out of date? Tell us or edit this page on GitHub. General information, not legal advice.