Operationalizing AI Governance: A DPIA + LLM Toolkit

AI systems introduce risks that extend beyond traditional data processing, including profiling, inference, dynamic outputs, model behavior, and third-party AI dependencies. These characteristics require additional assessment criteria that are not fully covered by standard DPIA methodologies.

The toolkit consists of two integrated components: a GDPR-aligned DPIA Core that evaluates privacy and compliance requirements, and an LLM Addendum that addresses AI-specific risks such as prompts, outputs, training data, model behavior, vendor dependencies, and AI governance obligations.

Organizations can embed the toolkit throughout the AI lifecycle from design and development to deployment and ongoing monitoring. Regular reassessments, clear ownership across privacy, legal, security, and AI teams, and continuous governance processes help ensure risks remain effectively managed as AI systems evolve.