# Worked customer-support DPIA

Synthetic organisation, roles and assessment findings. Proposed safeguards have not been tested; no DPO or supervisory authority approval is claimed.

Fictional assessment of wording assistance for customer replies. This completed teaching record reaches a redesign decision rather than asserting the original raw-ticket use is approved.

| Assessment element | Illustrative finding | Owner or follow-up |
| --- | --- | --- |
| Purpose and scope | Improve reply wording; no automated customer decision or sending. | Support owner defines the permitted task. |
| Original data flow | Ticket text → employee device → ChatGPT workspace → draft back to ticket. | Security maps stored copies and recipients. |
| Necessity and alternative | Generic wording examples can meet the initial purpose without raw tickets. | Support owner chooses the reduced-context design. |
| Lawfulness and transparency | Any later real-data use needs its Article 6 basis and relevant Article 9 analysis. | Privacy owner verifies grounds and information for customers. |
| Risk to individuals | Unnecessary identifiers, unexpected health details and misleading drafts could affect customers. | Privacy and support owners assess consequence and scope. |
| Proposed safeguards | No attachments/connectors in the example; generic inputs; human reply review. | Security verifies actual configuration; support tests the review procedure. |
| Residual uncertainty | Service terms, retention and effectiveness are not established for a real deployment. | Procurement and security obtain the missing evidence. |
| Illustrative decision | Do not start raw-ticket processing; begin with invented wording examples. | Reassess real-data scope and any Article 36 implications before a later change. |

## Review steps

- Trace every retained copy: Include the ticket, AI conversation, attachments, generated drafts and exported evidence.
- Test necessity: Explain why a generic description or approved template would not meet the proposed real-data purpose.
- Resolve the remaining risk: Record actual evidence and responsibilities; assess prior consultation where the legal threshold is met.

## Invented safe input

Rewrite this generic support message more clearly: “Please check the delivery instructions and contact our support team if they need updating.” Do not invent a customer, account number or personal circumstance.

## Illustrative disposition

Original proposal: paste raw tickets.
Decision in this teaching example: redesign; use generic wording context only.
Live-data approval: none represented.
Control validation: not run.
Review trigger: any proposal to add identifiable tickets, attachments, connectors or automatic replies.

## Source and scope

Guide: https://aona.ai/resources/guides/chatgpt-dpia-worked-example/

Source check: 21 September 2026. General information; no professional approval or installed-product result is represented.

- EU GDPR: Regulation (EU) 2016/679: https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng
- ICO: Guidance on AI and data protection: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/