Is assessment of inherent and residual risk required in a GDPR risk analysis?
ANSWER
Yes, when conducting a risk analysis under the GDPR, assessment of both inherent
and residual risk is recommended and often required for effective management of risk associated with personal data processing.
Inherent risk
Inherent risk is the risk that exists before any controls or safeguards are introduced. In other words, it is the primary risk associated with the personal data processing process, arising from the nature of the data processed, the manner of processing, the technologies used for processing, and also external factors such as cyber threats.
Residual risk
Residual risk is the risk that remains after all planned controls and safeguards have been applied. It is the risk that the organization must accept and manage because it cannot be completely eliminated.
Why are both assessments important?
- Comprehensive risk management:
- Inherent risk assessment helps understand what risks are associated
with personal data processing, regardless of existing controls. - Residual risk assessment helps evaluate the effectiveness of implemented safeguards and identify areas that still require attention.
- GDPR compliance:
- The GDPR requires organizations processing personal data to implement appropriate technical and organizational measures to ensure an appropriate level of security (Article 32 GDPR).
- Risk analysis, including assessment of inherent and residual risk, is a key element of meeting this requirement because it helps the organization identify, assess and manage risk.
- Informed decisions on safeguards:
- Through inherent risk assessment, the organization can identify which threats are most critical and require particular attention.
- Residual risk assessment allows evaluation of the effectiveness of implemented controls and, where necessary, introduction of additional safeguards.
