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A free AI DPIA template, with a worked example

A risk assessment (a DPIA) for using AI tools like ChatGPT and Copilot, in plain English. Copy the template, fill in the parts in [square brackets], and use the worked example for a 10-person accountancy practice as a guide.

Copy it into a Word or Google document to edit it.

Last checked .

How to use it

  1. 01

    Read the worked example below the template, so you know what good answers look like.

  2. 02

    Fill in each section for your own firm, with the people who actually use the AI tools.

  3. 03

    Have it signed off, act on the measures, and review it when you add a tool or something changes.

The template

[Firm name]: risk assessment (DPIA) for using AI tools

Prepared by: [name, role]. Date: [date]. Data protection lead: [name]. Version: [1.0].

1. What we're doing (description)

Which AI tools and plans: [for example ChatGPT Business, Microsoft Copilot signed in with work accounts].

What we use them for: [for example drafting client letters, summarising documents, checking spreadsheet formulas].

Whose personal data could be involved: [clients, clients' employees, our staff, others].

What kinds of personal data: [names, contact details, financial details, identifiers such as NI numbers or UTRs, any of the most sensitive kinds (special category data)].

Where the data goes: [the AI provider, the country it's stored in, and any sub-processors].

Who has access, and how long it's kept: [roles, and the provider's retention settings].

2. Why we need it (necessity and proportionality)

The problem it solves: [for example, time spent drafting routine letters].

Our lawful basis: [for example, legitimate interests, with a short note of the balancing test].

Why this is proportionate: [why we need personal data at all for each task, and how we keep it to the minimum].

Other options we considered: [for example, not using AI, or using it only with no personal data].

3. Risks to people

For each risk, note how likely it is and how serious it would be: [low, medium or high].

- Personal data shared with a provider that has no contract with us (personal or free accounts).

- Data used to train the provider's AI.

- Data stored outside the UK without the right safeguards.

- Inaccurate output relied on, affecting a client.

- The most sensitive data (special category data) entered without the extra care it needs.

- Staff not knowing the rules, or not being told how their own use is recorded.

4. Measures to reduce the risks

For each risk, the measure and who owns it: [measure, owner, date].

- Approve business plans only, with a data processing agreement, and block or warn about personal accounts.

- Check each provider's training setting and data location.

- Keep personal data out of prompts where the task doesn't need it.

- Publish an AI policy, train the team, and record who has read it.

- Check AI output before it's relied on.

- Tell staff what's recorded about their AI use, and why.

Remaining risk after these measures: [low, medium or high].

5. Sign-off

Measures approved by: [name, role, date].

Remaining risk accepted by: [name, role, date]. If the remaining risk is still high, consult the Information Commission (ICO) before you start.

Data protection lead's advice: [summary, and whether it was followed].

Next review: [date], or sooner if we add a tool or a provider changes its terms.

Worked example: a 10-person accountancy practice (made-up example)

Made-up example, not a real client. Harbour & Lane Accountants has 10 people. It uses ChatGPT Business and Microsoft Copilot signed in with work accounts.

Description: drafting client letters and tax reminders, summarising HMRC letters, and checking payroll formulas. Personal data: client names, contact details, UTRs, NI numbers, bank details and payroll data. Both providers are business plans with a data processing agreement, and neither trains on what's typed by default.

Necessity: the AI saves around [x] hours a week on routine drafting. For most tasks the AI doesn't need real client details, so the practice decides to keep them out of prompts where it can.

Main risks: a member of staff using a personal ChatGPT account for client work (likely, serious); payroll data pasted to check a formula (likely, serious); an HMRC letter summary relied on without checking (possible, moderate).

Measures: personal AI accounts blocked for client work; client details swapped for placeholders before prompts are sent; an AI policy published and acknowledged by all 10; output checked before it's sent to a client. Remaining risk: low.

Sign-off: approved by the managing partner, [date]. Review in six months.

Fill in the parts in [square brackets]. General information, not legal advice.

Let Saiela draft it for you

Filling in a DPIA from scratch takes time, and it goes out of date the moment you approve a new tool.

On the Team plan, Saiela drafts your DPIA from what its console already knows: which AI tools you've approved, what data your team handles and what your policy says. When something changes, such as a new tool being approved, the DPIA is flagged for review. You review and sign it off; it isn't legal advice.

See how the compliance centre works

Questions

Do I need a DPIA to use ChatGPT or Copilot?

Usually, yes. The Information Commission (ICO) says that in the vast majority of cases, using AI involves processing likely to result in a high risk to people's rights and freedoms, which triggers the legal requirement for a DPIA.

What does a DPIA for AI need to include?

A description of the processing (its nature, scope, context and purposes), why it's necessary and proportionate, the risks to people, the measures to reduce them, and the risk that remains. This template follows that structure.

Who should sign off the DPIA?

Someone senior who can accept the remaining risk, such as a partner or director, with advice from your data protection lead. If the remaining risk is still high after your measures, you must consult the ICO before you start.

How often should we review it?

Whenever you add an AI tool, a provider changes its terms, or you start using AI for something new, and at least once a year.

Sources

Stuart Kinsey

Stuart Kinsey

Co-founder of SimpleKPI

Stuart has worked in creative and analytical services for over 25 years and co-founded SimpleKPI in 2007. He writes about how small firms can use AI safely and what UK data protection law expects.

Stuart on LinkedIn

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