PIA-Bench: Towards Automated Privacy Impact Assessment with Large Language Models

Abstract

Privacy impact assessment (PIA) is a critical instrument for institutions to proactively identify privacy risks and develop mitigation strategies before system deployment. While mandated across regulatory and institutional contexts, executing PIA requires extensive privacy and technical expertise, posing a particular challenge for teams without access to such resources. Prior work shows the potential of leveraging large language models (LLMs) to assist practitioners' privacy decisions, but little is known about how accurately and reliably LLMs can automate PIA. To this end, we develop PIA-Bench, the first open benchmark for evaluating LLMs on real-world PIAs. We first audited 499 expert-authored PIAs published by US federal agencies and curated 73 structured PIAs, comprising a total of 451 privacy risk and 831 mitigation items, to evaluate LLMs' ability to assess privacy risks and propose mitigations of complex systems. Our results show that off-the-shelf LLMs produce meaningful assessments and identify avenues for future improvement. Finally, we call for improving domain-specific workflows for LLM agents, developing accountable LLM infrastructure, and designing new quality standards for PIAs.