Compliance

Privacy Impact Assessment (PIA)

Assessment documenting privacy implications of information practices.

How the laws define this

Privacy Impact Assessments are consistently defined as systematic or documented processes designed to identify, assess, and mitigate privacy risks prior to launching new projects, systems, services, or processing activities involving personal information. The key divergence lies in which entities are bound and what specific triggers apply. The Protection of Privacy Act (Bill 33) applies to public bodies creating new programs, systems, or services, while the Enhancing Digital Security and Trust Act, 2024 applies to institutions collecting personal information or altering processing purposes, requiring ongoing updates and oversight by the Information and Privacy Commissioner under amended FIPPA provisions introduced by Bill 194/EDSTA. Law 25 expands mandatory triggers to high-risk technologies like AI or biometrics, cross-border data transfers, and electronic service delivery. Distinct from these statutory mandates, IEEE 7002-2022 — Standard for Data Privacy Process presents the assessment as a mechanism to confirm the effective implementation of necessary privacy controls for ongoing compliance.

Synthesised from the 4 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first.

Jurisdiction	Instrument	Status	What is distinctive
Ontario, Canada	Enhancing Digital Security and Trust Act, 2024	In Force	Requires institutions to conduct and keep current the assessment prior to collecting personal information or changing processing purposes, with review by the Information and Privacy Commissioner.
Quebec, Canada	An Act to modernize legislative provisions as regards the protection of personal information (Law 25)	In Force (Amended)	Mandates assessments specifically for projects involving information systems acquisition, development, overhaul, electronic service delivery, cross-border transfers, or high-risk technologies.
Alberta, Canada	Protection of Privacy Act (Bill 33)	In Force	Requires public bodies to perform the process before implementing new programs, systems, or services involving personal information collection, use, or disclosure.
IEEE	IEEE 7002-2022 — Standard for Data Privacy Process	In Force	Describes it as a non-binding standard process for identifying risks in new projects and confirming implementation of privacy controls within systems engineering.

What it triggers

In Ontario, Canada, under the Enhancing Digital Security and Trust Act, 2024, institutions must conduct and keep current a PIA prior to collecting personal information or changing its processing purposes.source
In Quebec, Canada, under Law 25, organizations must conduct a PIA for projects involving the acquisition, development, or overhaul of information systems, electronic service delivery, cross-border data transfers, or high-risk technologies.source
In Alberta, Canada, under the Protection of Privacy Act (Bill 33), public bodies must undertake a PIA before implementing new programs, systems, or services that involve personal information.
IEEE 7002-2022 sets out a PIA as a systematic process for identifying privacy risks and confirming privacy controls in systems engineering.

Definitions (4)

A documented assessment that institutions must conduct (and keep current when there are significant changes) prior to collecting personal information or changing its processing purposes; used to identify and mitigate privacy risks, and subject to review by the Information and Privacy Commissioner under the amended FIPPA provisions introduced by Bill 194/EDSTA.

Enhancing Digital Security and Trust Act, 2024Definition 1 of 4

A mandatory assessment required for projects involving the acquisition, development, or overhaul of information systems, electronic service delivery, cross-border data transfers, or high-risk technologies like AI or biometrics, to identify and mitigate privacy risks.

An Act to modernize legislative provisions as regards the protection of personal information (Law 25)Definition 2 of 4

A systematic process required under the Act for public bodies to identify, assess, and mitigate potential privacy risks before implementing new programs, systems, or services that involve the collection, use, or disclosure of personal information.

Protection of Privacy Act (Bill 33)Definition 3 of 4

A Privacy Impact Assessment (PIA) is a systematic process used to identify and assess the privacy risks of new projects, systems, or processes. It also serves as a mechanism for confirming the effective implementation of necessary privacy controls and measures within a system, aiding in ongoing risk management and compliance.

IEEE 7002-2022 — Standard for Data Privacy ProcessDefinition 4 of 4

Not to be confused with

Data Protection Impact Assessment (DPIA)

DPIA specifically targets privacy risks and mitigations for AI systems, while PIA applies more broadly to information practices or projects.

DPIA

DPIA refers to the GDPR-mandated Data Protection Impact Assessment, whereas PIA is used in Canadian provincial laws and standards.

Questions and answers

When is a Privacy Impact Assessment required in Ontario?

Under the Enhancing Digital Security and Trust Act, 2024, institutions must conduct a PIA prior to collecting personal information or changing its processing purposes, and keep it current with significant changes. It is subject to review by the Information and Privacy Commissioner.

What projects trigger a PIA in Quebec?

Quebec's Law 25 requires a PIA for projects involving the acquisition, development, or overhaul of information systems, electronic service delivery, cross-border data transfers, or high-risk technologies like AI or biometrics.

Is IEEE's PIA definition legally binding?

No, IEEE 7002-2022 is a non-binding standard that describes PIA as a process for identifying risks and confirming privacy controls in systems engineering lifecycles.