Identification of Compositional Risks in Data Protection Impact Assessments and Beyond
Research formalises how privacy risks emerge from the composition of multiple data processors—a blind spot in standard DPIAs that grows as enterprises rely on complex supply chains under GDPR.
Summary written by editorial AI · Source link below
arXiv:2609.01201v1 Announce Type: new Abstract: When personal data is processed in a distributed manner by cooperating service providers, privacy risks may emerge solely from the choice of data processors included in the composition. For instance, different data processors may unknowingly rely on the same cloud provider, allowing for unintended linkability of personal data at that very provider. As such compositional risks to privacy are beyond the scope of each individual risk assessment, they
Editorial Analysis
EU enterprises using multi-vendor service chains may underestimate compositional privacy risks that only surface when processor interactions are analysed jointly, creating potential GDPR exposure.
Require compositional risk assessment as part of every DPIA involving more than one external data processor.
Hidden privacy risks can emerge when multiple data processors interact, and standard impact assessments often miss them—relevant for GDPR governance.
Forward-looking interpretation drafted by editorial AI under human review — not a reproduction of the source. See methodology.
External link — opens at arXiv Crypto & Security in a new tab.
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