IMPACT.

18 DPIA reviews scoped against new processing activities. 5 marked high-risk but never escalated to DPO sign-off. 2 processing changes shipped before DPIA closure.

A DPIA you didn't finish is a DPIA that didn't happen.

DP-011 · facial-similarity match HIGH RISK

Biometric template inference. Shipped 2025-10-01 with open DPIA.

Halt processing, complete DPIA, re-launch with consent gate.