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    Step-by-Step: Conducting Your First FRIA

    A practical walkthrough of the Fundamental Rights Impact Assessment process, with templates and examples.

    James RobertsonJanuary 10, 202514 min read

    Step-by-Step: Conducting Your First FRIA

    A Fundamental Rights Impact Assessment (FRIA) is required for certain deployers of high-risk AI systems. This guide walks you through the process step by step.

    When is FRIA Required?

    You must conduct a FRIA if you are:

    • A public authority deploying high-risk AI
    • A private entity providing public services using high-risk AI
    • Deploying certain Annex III high-risk systems

    The FRIA Process

    Step 1: Preparation

    Gather your team:

    • System owner
    • Legal/compliance representative
    • Data protection officer
    • Subject matter experts for affected groups

    Collect documentation:

    • Provider's instructions for use
    • Technical documentation
    • Data flow diagrams
    • Existing impact assessments

    Step 2: Describe the Process

    Document:

    • Your organization's process where AI is used
    • The AI system's role in that process
    • Decisions influenced by the AI
    • Human oversight arrangements

    Step 3: Identify Affected Persons

    Consider:

    • Who is directly affected by AI outputs?
    • Are there vulnerable groups?
    • How many people are affected?
    • What's the frequency of impact?

    Step 4: Assess Risks to Fundamental Rights

    Evaluate risks across categories:

    • Non-discrimination and equality
    • Privacy and data protection
    • Freedom of expression
    • Access to services
    • Due process and contestability

    For each risk:

    • Assess likelihood (Low/Medium/High)
    • Assess severity (Low/Medium/High)
    • Document your reasoning

    Step 5: Define Mitigations

    For each identified risk:

    • What controls reduce the risk?
    • Who is responsible for each control?
    • How will effectiveness be measured?

    Step 6: Document Oversight Measures

    Describe:

    • Who provides oversight
    • Their competencies and training
    • Their authority to intervene
    • Escalation procedures

    Step 7: Approval and Notification

    Complete:

    • Internal approval workflow
    • Document approvers and dates
    • Notify market surveillance authority (if required)

    Get the Template

    Download our FRIA Template to structure your assessment.

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