The Information Accountability Foundation has studied the definition of risk in privacy risk management. In an interim report, the IAF found "while risk-based was the GDPR's intent", not enough emphasis was placed on "risk of what?" Consequently, definitions of risk vary. The IAF said its hypothesis is "that the failure to gain a consensus on the risks to be managed has led to a less than optimal implementation of a risk-based approach to data protection and that creating a consensus on the defined risks would lead to prioritisation and then strategic management of them," adding it will continue to seek an answer to the "risk of what?" question over the coming year.
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