DPIA and LIA templates for analytics
Templates for a legitimate interests assessment (LIA) and a data protection impact assessment (DPIA) outline covering Privatus Analytics, ready to fill in.
These templates cover Privatus Analytics only. They are starting points, not legal advice and not a finished assessment. The conclusions are yours to reach: fill in the bracketed parts, add your other processing, and have your data protection officer or counsel review them.
Legitimate interests assessment (LIA)#
1. Purpose test#
- Interest: understanding how visitors use [website] to improve its content, performance and conversion, and measuring marketing effectiveness.
- Why it matters: [e.g. prioritizing content, fixing broken pages, deciding campaign budgets].
- Is the interest legitimate? [Your assessment, e.g. audience measurement is a normal activity for a website operator.]
2. Necessity test#
- Is processing necessary? Counting visits, sources and pages requires processing requests to the website. Privatus Analytics minimizes this: no cookies, no device storage (except a visitor's own opt-out flag), no persistent identifiers, IP addresses used in memory only and never stored.
- Less intrusive alternatives? [Explain why you need visit and daily visitor counts, e.g. to measure conversion rates and campaign effectiveness, rather than raw pageview totals only.]
3. Balancing test#
| Factor | Assessment |
|---|---|
| Nature of data | A pseudonymous visit key exists for at most one UTC day and is never stored in the database. Stored events carry a random visit id, no IP address, no raw User-Agent and no persistent identifier. Location is country only. No special categories are requested. The PII scrubber redacts common patterns of accidental personal data |
| Reasonable expectations | [e.g. visitors expect websites to count visits, and our privacy policy explains it] |
| Impact on individuals | [Your assessment.] Facts: no cross-site or cross-device tracking, no advertising use, no visitor profiles across days |
| Safeguards | No cookies, daily salt that expires and is never saved, IP and User-Agent processed in memory only and never stored, visitor opt-out, GPC honored (on by default), DPA and SCCs with Privatus Analytics |
| Vulnerable groups | [Consider if your site targets children] |
Conclusion: [e.g. the legitimate interest is not overridden by the interests or rights of visitors.] [Date, name, role.]
Data protection impact assessment (DPIA) outline#
Whether a DPIA is required is for you to assess against the GDPR and your regulator's lists. If your organization does one, cover:
- Description: purposes (audience measurement), data (see the data inventory), recipients (Privatus Analytics as processor and its subprocessors), retention ([your plan's retention]), locations (US processing and storage, IP and User-Agent in memory only, country-only location).
- Necessity and proportionality: lawful basis (legitimate interests, LIA above), minimization measures, transparency (privacy policy) and data subject rights (opt-out, and stored data has no IP address or persistent identifier, so we usually can't find the data of a particular visitor).
- Risks: re-identification of visitors (mitigated: salt destroyed daily, no IPs stored), accidental collection of personal data in URLs or properties (mitigated: PII scrubber, query stripping, path masks, redaction log), international transfer (mitigated: IP and User-Agent processed in memory only and never stored, SCCs) and unauthorized access to the dashboard (mitigated: roles, two-factor authentication, the audit log on paid plans and SSO on the Business plan).
- Measures and residual risk: [your assessment].
- Sign-off: [DPO opinion, decision, date].
The DPA and the subprocessor list are on our legal pages. The DPA includes our technical and organizational measures.