Data Protection Impact Assessment: Privacy by Design
EasyData’s revolutionary approach: WE DO NOT STORE CLIENT DATA. Real-time processing without persistent storage makes our services inherently privacy-friendly.
Request DPIA Consultation
Executive Summary
EasyData processes personal data exclusively on behalf of clients through OCR and document processing. The distinguishing principle: WE DO NOT STORE CLIENT DATA. All processing happens in real-time without persistent storage of personal data. This makes EasyData’s services inherently privacy-friendly and significantly minimizes risks.
1. Description of the Processing
1.1 Purpose of the processing
EasyData B.V. offers OCR (Optical Character Recognition) and document processing services to business clients and Dutch municipalities. The purpose is to digitize, recognize, extract and return structured data from documents in real-time.
🎯 Specific processing purposes:
- Real-time conversion of documents to searchable text
- Automatic extraction of data (invoice data, contract data, etc.)
- Classification and indexing of documents
- Validation and enrichment of extracted data
- Direct return to client via APIs
🔒 CORE PRINCIPLE
All processing happens in RAM memory. Documents are received, processed, returned and immediately deleted from memory. There is NO persistent storage of client documents or extracted personal data.
1.2 Categories of personal data
Regular personal data
- Name, address, city details
- Contact information (phone, email)
- Date and place of birth
- Social Security Number (government clients only)
- Identification numbers
- Financial data
- Employment data
Special categories of personal data
(Limited, only if explicitly agreed)
- Medical data (when processing healthcare documents)
- Criminal record data (only for government clients with legal basis)
1.3 Technical description of processing
1.4 Retention period
after processing
log files
(without personal data)
3. Risk Identification and Analysis
Due to the absence of persistent data storage, all risks are limited to the short processing time (seconds to minutes). This makes EasyData’s services inherently much safer than traditional processing services with data storage.
RISK 1: Unauthorized access during processing
Description: During the short processing time, someone could gain unauthorized access to documents in RAM.
Likelihood: Very low (strong access controls, isolated environment)
Impact: Significant (access to personal data)
Risk score: LOWRISK 2: Data breach during transport
Description: Interception of documents during transport to/from EasyData servers.
Likelihood: Very low (TLS 1.3 encryption, certificate pinning)
Impact: Significant
Risk score: LOWRISK 3: Incorrect document extraction/classification
Description: OCR errors lead to incorrect data extraction, impacting decision-making.
Likelihood: Low (high-quality OCR, validation, human verification at client)
Impact: Limited (client validates output)
Risk score: LOWRISK 4: Incomplete removal from RAM
Description: Theoretical risk that data remains in RAM after processing.
Likelihood: Very low (secure memory wiping, container isolation)
Impact: Limited (temporary, no persistence)
Risk score: VERY LOW4. Measures to Mitigate Risks
4.1 Technical measures
🔐 Transport & Encryption
- TLS 1.3 mandatory for all communication
- Certificate pinning for API connections
- No support for weak cipher suites
- End-to-end encryption option available
💾 In-Memory Processing
- All processing in RAM (no disk writes)
- Swap/pagefile disabled
- Secure memory wiping after each transaction
- Container-based isolation
- Automatic container destruction
🛡️ Access Control
- Multi-factor authentication (MFA) required
- Role-based access control (RBAC)
- Principle of least privilege
- Separated development, test and production environments
📊 Monitoring & Logging
- Real-time monitoring of all systems
- Detailed audit logs (no document content)
- Alerting for abnormal behavior
- SIEM integration for security events
🏢 Infrastructure
- European datacenter locations (primarily Netherlands)
- ISO 27001 certified hosting partners
- Redundant systems
- Automated security patching
- Regular penetration testing
👥 Personnel & Organization
- Pre-employment screening
- Mandatory privacy & security training
- Annual awareness training
- Code of conduct for employees
- Data Protection Officer (DPO) appointed
5. Residual Risks
✅ Conclusion on Residual Risks
After implementing all measures above, only minimal residual risks remain that are inherent to any form of IT services. All residual risks are very low to low and are accepted.
Prior consultation with Data Protection Authority: NOT NECESSARY
⚠️ Residual risks in detail
- Zero-day vulnerabilities: Continuous monitoring and rapid patching minimize exposure time
- Advanced persistent threats (APT): No-storage principle significantly limits potential damage
- Natural disasters/calamities: Redundant infrastructure ensures continuity, no data lost
6. Rights of Data Subjects
Because EasyData does not store personal data, many rights of data subjects are practically not enforceable at EasyData. The responsibility lies with the client (data controller).
Right of access (Art. 15 GDPR)
EasyData has no stored data to access. Data subject must contact the client.
Right to erasure (Art. 17 GDPR)
Automatically implemented by design – data is immediately deleted. No action needed at EasyData.
Right to rectification (Art. 16 GDPR)
Not applicable at EasyData. Client can have corrected documents reprocessed.
Right to restriction of processing (Art. 18 GDPR)
Client can stop processing by not submitting documents. EasyData stops immediately.
8. Specific Considerations
🔒 Special categories of personal data (Art. 9 GDPR)
EasyData only processes special categories of personal data if:
- Client has valid legal basis
- Additional processor agreement is concluded
- Extra security measures are implemented
- DPO has approved
🌍 Transfer outside EU
EasyData guarantees:
- All processing within the EU (primarily Netherlands)
- No transfer to third countries
- Sub-processors are EU-based
- No remote access from outside EU
🤖 Automated decision-making
OCR and data extraction is automated, but:
- EasyData does not make decisions about data subjects
- Output is used for human assessment
- No profiling or automated individual decision-making
- Responsibility lies with client
10. Conclusion and Recommendations
🎯 General Conclusion
EasyData’s OCR and document processing services do NOT pose a high risk to the rights and freedoms of data subjects, provided all described measures are maintained.
The distinguishing no-storage principle is the most important risk mitigation:
- No persistent storage = no data breach of historical data possible
- Limited exposure time (seconds/minutes) = minimal risk window
- Transient processing = privacy by design
- Full GDPR compliance = trust from clients and data subjects
💡 Recommendations
- Maintain the no-storage principle as core value of EasyData
- Actively communicate this distinguishing feature to (potential) clients
- Continue investing in security awareness for employees
- Renew this DPIA annually or upon significant changes
- Consider additional certification (ISO 27001, NEN 7510 for healthcare)
Frequently Asked Questions about EasyData’s DPIA
What makes EasyData’s no-storage principle so unique?
Unlike traditional document processing services, EasyData does NOT store client documents or personal data. All processing happens in real-time in RAM memory and data is immediately deleted after delivery to the client. This eliminates the biggest privacy risk: large-scale data breaches of historical data.
Is a DPIA legally required for OCR services?
A DPIA is required when there is a high risk to the rights and freedoms of natural persons (Article 35 GDPR). For traditional OCR services with data storage, this may be the case. However, due to EasyData’s no-storage principle, the risk is low, but we have still prepared a DPIA to ensure maximum transparency and compliance.
How does EasyData guarantee that data is truly deleted from RAM?
EasyData uses secure memory wiping technology and container-based isolation. Each processing job runs in an isolated container that is automatically destroyed after completion. Swap/pagefile is disabled on all processing servers to prevent RAM contents from being written to disk. Regular security audits and penetration tests verify these measures.
What happens in case of a data breach during processing time?
Due to the short processing time (seconds to minutes), exposure during an incident is minimal. EasyData informs the client within 24 hours of a (potential) data breach. Since no historical data is stored, the scope of a breach is inherently limited to documents being processed at that moment – no snowball effect possible.
How do data subjects exercise their GDPR rights at EasyData?
Because EasyData does not store personal data, most GDPR rights are automatically implemented (for example: right to erasure). For other rights (such as access), data subjects must contact the client (data controller), not EasyData. The client has full control over which documents are submitted for processing.
Is EasyData suitable for processing special categories of personal data?
Yes, EasyData can process special categories of personal data (medical, criminal) if the client has a valid legal basis according to Article 9(2) GDPR. We then conclude an additional processor agreement with extra safeguards and implement additional security measures. This only happens after approval from our Data Protection Officer (DPO).
Ready to work GDPR-compliant with maximum privacy protection?
EasyData’s no-storage principle combines maximum privacy protection with high-quality OCR results. Our DPIA demonstrates that we do NOT pose a high risk to data subjects. Join 400+ Dutch organizations that trust our privacy-by-design approach.
⭐ About the author
