Data Protection Impact Assessment: A Protection Tool for Migrants Using ICT Solutions

Smart devices have become ubiquitous in everyday life, and it is commonplace that migrants are among the users of connected tools. With the realization that migrants rely on connectivity for multiple purposes, including to access information and services, many initiatives started working on developing ICT tools to assist migrants to integrate into their new society. Technological tools, however, come with inherent risks, many of which are linked to the processing of personal data of their users. This is especially true for migrants, who are often vulnerable due to their migration status, which is not always secure in the host country. To mitigate these risks, we argue that an expanded data protection impact assessment, analyzing not only the impacts related to data protection, but also to the specific situation of migrants, should be conducted at the outset of any technology development project to influence the development of safe and reliable ICT tools for this target population. A practical example of the application of such an assessment is provided, based on the authors’ experience as legal advisors in the REBUILD project, which is one of the current initiatives in the EU aiming to develop ICT tools for migrant integration.