  In this paper, we critically examine the effectiveness of the requirement to
conduct a Data Protection Impact Assessment (DPIA) in Article 35 of the General
Data Protection Regulation (GDPR) in light of fairness metrics. Through this
analysis, we explore the role of the fairness principle as introduced in
Article 5(1)(a) and its multifaceted interpretation in the obligation to
conduct a DPIA. Our paper argues that although there is a significant
theoretical role for the considerations of fairness in the DPIA process, an
analysis of the various guidance documents issued by data protection
authorities on the obligation to conduct a DPIA reveals that they rarely
mention the fairness principle in practice.
