The correct answer is Whether the processing is likely to create a high risk to individuals' rights and freedoms. This threshold is what determines when a data protection impact assessment is mandated under the GDPR.

Under Article 35 of the GDPR a DPIA is required where processing is likely to result in a high risk to the rights and freedoms of natural persons. Supervisory authorities and guidance from the European Data Protection Board focus on factors such as the nature scope context and purpose of processing and whether it involves systematic monitoring special category data or large scale profiling when judging likelihood and severity of risk.

The total number of personal records that will be handled is not by itself the main determinant. Volume can increase impact but the law looks at the likelihood and severity of harm to individuals rather than a single numeric threshold.

Whether personal data will be transferred to countries outside the European Economic Area is important for lawful transfers and adequacy requirements. Transfers can raise risks but they only trigger a DPIA when they contribute to a high risk to individuals' rights and freedoms.

The size and staffing levels of the organisation operating the processing are not the trigger for a DPIA. Organizational scale may affect mitigation capacity but the requirement depends on the risks posed by the processing activity itself.

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