개인정보보호위원회개인정보 영향평가 수행안내서(2025. 10.)

2025-11-20
조회수 241

게시일 : 2025-12-12

의견 수렴 후 최종버전이 공개되었습니다.

업무에 참고하세요.



ㅇ 발간 목적

   본 안내서는 공공기관의 인공지능(AI) 도입·활용 시 개인정보보호 강화 등을 위해 개정된 구체적인 평가기준과 방법을 안내할 목적으로 마련되었습니다.

ㅇ 발간 이력

- '25.10. 초안 공개 및 의견수렴 (국가정보자원관리원 화재로 인해 한국인터넷진흥원 홈페이지에 게시)

- '25.11. 개인정보위 공식 홈페이지에 게시

- '25.12. 의견수렴('25.10.31~11.20.) 내용 일부 반영 및 일부 오타 수정(397쪽 근거 조문 등)


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게시일 : 2025-10-31


개인정보 영향평가 수행안내서가 공개되었습니다.

아직은 최종버전은 아니고 이해관계자 의견 수렴 후 최종버전을 공개할 예정인가 봅니다.

2024년 개인정보 영향평가 수행안내서와 차이점은 다음 정도로 보입니다.


구분2024년 버전2025년 버전비고
중점 신설 내용요약본 미제출 과태료 규정,
자동화된 결정 대응
인공지능(AI) 평가분야 및 항목 신설AI 시스템 평가 기준 추가
평가 항목 구성총 5개 영역, 27개 평가분야총 5개 영역, 27개 평가분야
(구성은 변경됨)
분야 재조정
특정 IT 기술 분야
(제5영역)
5.1 고정형 영상정보처리기기5.1 고정형 영상정보처리기기RFID 삭제, AI 신설
5.2 RFID5.2 이동형 영상정보처리기기 (순서 변경)
5.3 생체인식정보5.3 생체인식정보
5.4 위치정보5.4 위치정보
5.5 가명정보5.5 가명정보
5.6 이동형 영상정보처리기기5.6 자동화된 결정 (순서 변경)
5.7 자동화된 결정5.7 인공지능(AI) (신설)


업무에 참고하시기 바랍니다.




[목차]

I 총론

제1절 개인정보 영향평가 개요 ····································································· 10

1. 개념 ······························································································ 10

2. 목적 및 필요성 ·············································································· 10

3. 평가 대상 ······················································································ 10

4. 평가 시기 ······················································································ 13

5. 평가 수행 주체 ·············································································· 14

6. 평가 수행 체계 ·············································································· 14


제2절 용어정의 및 추진근거 ········································································ 15

1. 용어정의 ······················································································· 15

2. 추진근거 ······················································································· 17


제3절 영향평가 수행 절차 요약 ··································································· 18


II 영향평가 수행절차

제1절 영향평가 사전준비 단계 ····································································· 21

1. 사업계획의 작성 ··········································································· 21

2. 영향평가 기관 선정 ······································································· 24

제2절 영향평가 수행단계 ············································································· 26

1. 영향평가 수행계획 수립 ································································ 26

2. 평가자료 수집 ··············································································· 31

3. 개인정보 흐름 분석 ······································································· 34

4. 개인정보 침해요인 분석 ································································ 57

5. 개선계획 수립 ··············································································· 69

6. 영향평가서 및 요약본 작성 ···························································· 72


제3절 이행단계 ··························································································· 86

1. 이행점검 ······················································································· 86


III 영향평가 항목

제1절 개인정보 영향평가 항목 개요 ····························································· 90


제2절 개인정보 영향평가 항목 설명 ·························································· 101

1. 대상기관 개인정보보호 관리체계 ················································ 101

1.1 개인정보보호 조직 ······························································· 101

1.2 개인정보 보호계획 ······························································· 106

1.3 개인정보 침해대응 ······························································· 113

1.4 정보주체 권리보장 ······························································· 118

2. 대상시스템의 개인정보보호 관리체계 ········································· 127

2.1 개인정보취급자 관리 ···························································· 127

2.2 개인정보파일 관리 ······························································· 132

2.3 개인정보 처리방침 ······························································· 139

2.4 공공시스템 내부 관리계획 ···················································· 147

3. 개인정보 처리단계별 보호조치 ···················································· 152

3.1 수집 ····················································································· 152

3.2 보유 ····················································································· 177

3.3 이용‧제공 ·········································································· 181

3.4 위탁 ····················································································· 202

3.5 파기 ····················································································· 210

4. 대상시스템의 기술적 보호조치 ···················································· 218

4.1 접근권한 관리 ······································································ 218

4.2 접근통제 ·············································································· 244

4.3 개인정보의 암호화 ······························································· 263

4.4 접속기록의 보관 및 점검 ······················································ 275

4.5 악성프로그램 등 방지 ··························································· 286

4.6 물리적 접근방지 ·································································· 290

4.7 개인정보의 파기 ·································································· 294

4.8 기타 기술적 보호조치 ··························································· 297

4.9 개인정보 처리구역 보호조치 ··················································· 306

5. 특정 IT 기술 활용 시 개인정보보호 ············································· 311

5.1 고정형 영상정보처리기기 ····················································· 311

5.2 이동형 영상정보처리기기 ····················································· 324

5.3 생체인식정보 ······································································· 331

5.4 위치정보 ·············································································· 334

5.5 가명정보 ·············································································· 338

5.6 자동화된 결정 ······································································ 363

5.7 인공지능(AI) ········································································ 366


부록 1. 개인정보 영향평가서 양식 ····························································· 403

부록 2. 개인정보 영향평가 FAQ ······························································· 445


출처 : 개인정보 영향평가 수행안내서(2025.10. 개정)

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