Risk-Based Approach

A privacy compliance methodology requiring organizations to tailor data protection measures to the specific risks posed by their processing activities rather than applying uniform requirements regardless of risk level. Under GDPR Article 24, controllers must implement measures 'appropriate to the risk' considering factors like processing nature, scope, context, purposes, and likelihood and severity of risks to individuals' rights and freedoms. This means healthcare providers processing sensitive medical data need more robust controls than businesses collecting basic contact information for newsletters. Risk-based approaches require: identifying processing activities, assessing associated risks, implementing controls proportionate to those risks, documenting decisions, and regularly reviewing risk postures. This methodology recognizes resource constraints and encourages pragmatic prioritization—organizations should focus most attention on highest-risk processing. However, 'low risk' doesn't mean 'no compliance'—basic principles like lawfulness, transparency, and security apply universally. Risk-based approaches are increasingly prevalent in privacy regulations worldwide, emphasizing accountability and proportionality over prescriptive requirements.