Your fundraising team has a new partnership opportunity. Marketing wants to launch a new data enrichment service. IT is proposing a vendor consolidation. These are all revenue-driving or efficiency-generating initiatives, and they're excited to move forward.

Then someone asks: "Do we need a DPIA for this?"

Suddenly, what felt like forward momentum feels like a roadblock. Teams worry that "doing privacy right" means slowing down or saying no to good ideas. But a Data Protection Impact Assessment (DPIA) — sometimes also called a Privacy Impact Assessment (PIA) or a Data Protection Assessment (DPA) — doesn't have to kill momentum. When managed strategically, it can actually accelerate confidence in your decision-making.

What is a DPIA, and when do you need one?

A DPIA is a structured process for identifying and mitigating privacy risks before launching a new initiative, tool, vendor partnership, or data use. Under GDPR and many U.S. state laws, DPIAs are required for processing that is "likely to result in a high risk to the rights and freedoms of individuals" — which includes things like large-scale profiling, automated decision-making, processing sensitive data, or systematic monitoring.

But even when not legally required, DPIAs are often a smart strategic practice. They help you:

• Surface risks before they become problems
• Document your decision-making for future audits or board questions
• Ensure stakeholders are aligned on what data will be used and how
• Build trust with donors and constituents by showing you've thought through privacy implications

The key question isn't just "Do we legally need a DPIA?" but "Would a DPIA help us make a better, more defensible decision?"

Why DPIAs feel like they slow things down

Most organizations struggle with DPIAs because they approach them as a compliance gate at the end of the process or something legal or privacy has to "sign off on" before launch. By that point:

• The vendor has been selected and contracts are being negotiated
• Teams have already invested time and energy in the initiative
• Timelines are tight and expectations are set
• Any concerns raised feel like blockers, not helpful input

When privacy review happens this late, it creates tension. Teams feel like privacy is saying "no" to good ideas. Privacy teams feel like they're being asked to rubber-stamp decisions that have already been made.

How to keep momentum: Assess risk in tandem, not in sequence

The most effective DPIAs happen alongside project planning, not after it. Here's how to structure the process so privacy assessment supports momentum rather than stopping it:

1. Start the DPIA conversation early — during scoping, not contracting

As soon as a new initiative is being discussed, ask the basic DPIA questions:

• What data will be collected, used, or shared? Do we have a business case for each of these fields?
• Who will have access to it, and for what purposes?
• What are the potential risks to individuals or to our organization?
• Do we have the right consent in place for this use?
• How will we take care of the data we collect?

You don't need a 20-page document at this stage. You need clarity on whether there are red flags that should shape vendor selection, contract terms, or project scope.

2. Make it a conversation, not a form

DPIAs are most useful when they surface questions and prompt discussion among stakeholders. Instead of handing a 50-question form to the project owner and waiting for answers, facilitate a working session where:

• The project owner explains the initiative and its goals
• Privacy, legal, IT, product, and fundraising/marketing discuss what data will be involved
• The group identifies risks together and brainstorms mitigations

This collaborative approach helps everyone understand the "why" behind privacy concerns, and often surfaces creative solutions that wouldn't emerge from a checklist.

3. Distinguish between "this won't work" and "we need to adjust the approach"

Most privacy concerns don't mean you can't do the project. They mean you need to do it differently. For example:

• Instead of sharing full constituent records with a vendor, can you share anonymized or aggregated data? Can you limit the data fields you're sharing?
• Instead of broad tracking across all domains, can you limit data collection to specific, consented interactions?
• Instead of signing on for a broad engagement with a new corporate partner, can you agree in advance to the data protection terms you're both willing to co-sign?

When you assess risk early, you have room to adjust the approach without derailing timelines. When you assess late, your only options are "approve as-is" or "block entirely."

4. Document decisions, not just risks

A DPIA should capture not only what risks exist, but what you decided to do about them and why. This documentation serves multiple purposes:

• It shows auditors or regulators that you took privacy seriously
• It helps future teams understand why certain choices were made
• It creates institutional memory so you're not re-litigating the same questions every time

The goal isn't perfection; it's defensibility. You want to be able to say: "We identified these risks, we considered these options, and here's why we chose this path." The key question: Could you sit across from a donor and explain why you chose this path?

5. Recognize when you need external support

Not every DPIA requires a consultant. But there are situations where bringing in strategic advisory support can keep things moving:

• You're entering unfamiliar territory (e.g., first time using AI for constituent modeling, launching in a new regulatory jurisdiction)
• Internal stakeholders have conflicting risk tolerances and you need a neutral facilitator
• The DPIA is surfacing systemic issues (e.g., your consent management isn't working as expected, you don't have clarity on vendor data use, etc)
• Leadership needs an independent assessment to make a confident decision

In these cases, an advisor can help you structure the process, facilitate the discussion, and translate privacy concepts into operational terms that move the project forward.

The real goal: Privacy that supports growth, not stalls it

A well-managed DPIA doesn't slow down revenue-driving initiatives. It de-risks them. It helps you move forward with confidence that you've thought through the implications, documented your reasoning, and made choices that align with your organization's values and legal obligations.

When privacy is treated as a strategic partner in project planning rather than a compliance gate at the end, teams start to see it as a source of clarity and confidence, not a barrier to innovation.

Need help managing a DPIA process or building a framework for ongoing privacy assessments? I work with nonprofits and universities to structure privacy decision-making that supports growth, trust, and forward momentum. Book a discovery call to discuss how I can help.