Data Protection Impact Assessment
Pursuant to nFADP Art. 22 / GDPR Art. 35
1
Project Description
Project Title
Data Controller
Processing Description
Pre-filled
AIAgens AI voice assistant handles incoming phone calls for appointment booking, modification, and cancellation. The system uses real-time speech-to-text conversion, processes natural language for scheduling, and integrates with the practice's calendar system.
Purpose of Processing
- Automated appointment booking outside business hours
- Reduction of caller wait times
- Efficient resource utilization
2
Data Flows
Data Flow Diagram
Patient Calls
→
Voice (Real-time)
→
AI Processing
→
Appointment Data
→
Calendar
Data Categories Processed
| Category |
Data Elements |
Retention |
Location |
| Voice Data |
Audio stream |
None (real-time) |
EU |
| Triage Data (Transcripts) |
Transcript (no audio) |
Zero retention (real-time processing); long-term: controller |
EU (Germany) |
| Contact Data |
Name, phone |
Per contract |
EU (Germany) |
| Appointment Data |
Date, time, type |
Per contract |
Your calendar |
3
Necessity Assessment
Legal Basis
-
Consent (Art. 6(1)(a) GDPR / Art. 31 nFADP)
-
Contract performance (Art. 6(1)(b) GDPR)
-
Legitimate interest (Art. 6(1)(f) GDPR)
Proportionality
Assessment
Processing is limited to the minimum necessary for the purpose. Voice data is not retained, only extracted appointment details are stored. The data minimization approach ensures proportionality.
4
Risk Assessment
Unauthorized access
Low
Medium
Low
TLS 1.3, MFA, audit logs
AI misinterpretation
Medium
Low
Low
Confirmation protocols, human escalation
Data loss
Low
Medium
Low
Daily backups, geo-redundancy
Third-party breach
Low
High
Medium
DPA, SOC 2 certification
5
Mitigation Measures
| Measure |
Implemented |
Responsible |
| TLS 1.3 encryption |
✓ Yes |
AIAgens |
| AES-256 encryption (at rest) |
✓ Yes |
AIAgens |
| AI self-identification |
✓ Yes |
AIAgens |
| Human escalation option |
✓ Yes |
AIAgens |
| Patient consent |
Pending |
[Your org.] |
| Staff training |
Pending |
[Your org.] |
6
Sign-off
Overall Risk Assessment
Conclusion
Residual risk is assessed as LOW. Technical and organizational measures implemented adequately mitigate identified risks. Processing may proceed with documented safeguards in place.
Project Owner
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Date:
DPO / Advisor
(if applicable)
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