Privacy Risk Management Process

The Privacy Risk Management Process is a systematic, iterative governance discipline that identifies, analyzes, evaluates, and treats risks arising from the collection, processing, storage, sharing, or disposal of personal data. Within ISACA's CDPSE framework, it operates as a structured cycle—not a one-time audit—encompassing five sequential phases: (1) Risk Identification: cataloguing data assets, processing activities, and threat scenarios; (2) Risk Analysis: assessing likelihood and impact using qualitative matrices or quantitative financial models; (3) Risk Evaluation: prioritizing risks against an established risk appetite and tolerance thresholds; (4) Risk Treatment: selecting and implementing controls—avoid, mitigate, transfer, or accept; and (5) Risk Monitoring: tracking residual risk, measuring control effectiveness, and feeding results back into the next cycle. It is NOT a generic cybersecurity vulnerability assessment, NOT a one-time compliance checkbox exercise, and NOT synonymous with a single Data Protection Impact Assessment (DPIA)—although DPIAs are a mandatory input tool within the process for high-risk processing under GDPR Article 35.