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Identification of Compositional Risks in Data Protection Impact Assessments and Beyond

Research formalises how privacy risks emerge from the composition of multiple data processors—a blind spot in standard DPIAs that grows as enterprises rely on complex supply chains under GDPR.

Summary written by editorial AI · Source link below

Filed by arXiv Crypto & Security1 min readRead at source ↗

arXiv:2609.01201v1 Announce Type: new Abstract: When personal data is processed in a distributed manner by cooperating service providers, privacy risks may emerge solely from the choice of data processors included in the composition. For instance, different data processors may unknowingly rely on the same cloud provider, allowing for unintended linkability of personal data at that very provider. As such compositional risks to privacy are beyond the scope of each individual risk assessment, they

Editorial Analysis

Framed for the Compliance & GRC desk

Why it matters

When multiple processors handle personal data in a service composition, hidden compositional privacy risks can emerge that single-provider DPIAs miss—directly relevant to GDPR and NIS2 supply-chain obligations.

What to do

Extend your DPIA methodology to include compositional risk analysis across all data processors in multi-provider service chains.

Board brief

Hidden privacy risks can emerge when multiple data processors interact, and standard impact assessments often miss them—relevant for GDPR governance.

Forward-looking interpretation drafted by editorial AI under human review — not a reproduction of the source. See methodology.

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