What Does A Data Protection Manager Do?

WHAT DOES A DATA PROTECTION MANAGER DO?

Published: October 2, 2024 - The Data Protection Manager plays a crucial role in a distributed security and technology team, focusing on the establishment and maintenance of data protection technical controls. This position is pivotal in aligning data protection policies and procedures with corporate governance and risk management frameworks. The manager also ensures the secure operation and monitoring of data across various platforms, which is essential for supporting a dispersed remote workforce.

A Review of Professional Skills and Functions for Data Protection Manager

1. Data Protection Manager Duties

Strategy Support: Assist the Group DPO in forming and delivering strategies to grow the maturity of the business in data protection and privacy.
Query Response: Respond to data protection and privacy queries from across the business and from customers.
Documentation Maintenance: Ensure that the documentation under Article 30 of the GDPR is maintained and kept up-to-date.
Regulatory Assistance: Assist with regulatory enquiries.
Incident Team Participation: Be part of the incident management team when a personal data incident occurs.
Disclosure Response: Respond to requests for disclosure from law enforcement, etc.
Audit Conduct: Conduct data protection audits and DPIAs.
Training Management: Provide training and manage the online training portal.
Communication Planning: Take part in and help plan communication activities.
Contractual Advice: Advise on contractual requirements for new suppliers and business partners.

2. Data Protection Manager Details

Framework Assistance: Assist with the development of the data protection framework across the Group.
Legislation Advising: Advise the Company in monitoring compliance with UK and EU privacy legislation including the UK GDPR, EU GDPR, Data Protection Act 2018, and the Privacy and Electronic Communications Regulations.
PDPA Compliance Advising: Advise the Company in monitoring compliance with the Personal Data Protection Act (PDPA), liaising with local compliance suppliers/contractors.
Breach Investigation Assistance: Assist with data breach investigations and remedial actions taken, reporting breaches internally.
Risk Identification: Proactively identify business risks and issues in relation to data protection.
DPIA Conduct: Carry out DPIAs to assess and advise on controls necessary to mitigate data security risks.
Query Point of Contact: Act as the point of contact for any data protection queries.
Data Subject Contact: Act as point of contact for data subjects.
Document Review: Review documents and records relevant to the service provision.
Compliance Promotion: Promote a culture of compliance, control, and transparency in handling personal data by working with internal and external stakeholders.
Business Monitoring: Monitor compliance across the business.

3. Data Protection Manager Responsibilities

Team Collaboration: Work in the team of the North Europe Local Privacy Officer/Data Protection Officer.
Agreement Support: Support the business in reviewing agreements, completing formalities, and issuing recommendations.
Privacy Implementation Management: Manage smooth implementation of privacy-related requirements and actively support the business in meeting legal, corporate, and local requirements.
Formalities Completion: Complete necessary formalities with Data Protection Authorities (DPAs).
PDPA Conduct & Review: Conduct & review local Personal Data Protection Assessments (PDPAs).
Employee Training: Train to improve knowledge among employees/contractors.
Local Training Provision: Provide training locally. Participate in communications and events organized by the Data Protection Office.
Training Participation: Participate in trainings by GPO (Group Privacy Office) & train local teams.
Breach Management: Manage with the Data Protection Officer the personal data breaches and data subject requests.
Documentation Maintenance: Maintain local data protection documentation on policies & processes.
Register Maintenance: Maintain and update the register of processing activities, training records, privacy notices, consent forms, contractor & external provider’s management documentation, security measures, etc.

4. Data Protection Manager Job Summary

Regulation Familiarity Maintenance: Maintain familiarity with applicable privacy regulations, including GDPR and comparable regulations.
Policy Support and Advice: Provide support and advice to relevant stakeholders to ensure implementation of the Group Data Protection Compliance Policy as well as locally applicable data protection regulations.
Policy Evaluation: Evaluate existing corporate policies and make improvements.
Policy Oversight: Oversee implementation of and compliance with these policies, and ensure an appropriate level of data and privacy compliance within the organization.
Data Protection Governance: Oversee data protection governance for new products, projects, and initiatives.
Privacy Escalation Handling: Be the escalation point for customers who have privacy concerns.
Regulatory Interaction: Interact with local privacy regulatory bodies.
Culture Promotion: Promote a positive and effective data protection and privacy culture through training and awareness.
Privacy Monitoring: Monitor data privacy issues, working closely with IT and Compliance, ensure compliance with data governance and privacy requirements through auditing and risk management activities.
Incident Risk Advising: Advise on identification, risk assessment, and remediation of data incidents.

5. Data Protection Program Manager Accountabilities

Data Classification Collaboration: Work in collaboration with parent company contacts to understand and implement agreed upon data classifications.
Global Team Coordination: Coordinate with multiple teams across the company and in different countries and time zones.
Project Scope Definition: Define project scope, goals, and clear deliverables that support business and technology goals in collaboration with senior management and partners.
Data Inventory Development: Develop formalized data inventory encompassing all systems, apps, and vendors.
Data Mapping: Develop formalized data maps and data flow diagrams detailing process flows of restricted and confidential data, and how the data travels through different phases of the lifecycle.
Project Communication Management: Effectively communicate and manage project expectations and updates to sponsors, team members, and partners in a timely and clear fashion.
Project Scheduling: Plan, schedule, and track project timeline and milestones using PPM tool.
Task Delegation: Delegate tasks and responsibilities to appropriate team members.
Performance Measurement: Continually measure project performance to identify areas for improvement.
Data Standards Training: Establish and implement training regarding data classification standards for all associates.
Technical Meetings Leadership: Hold regular technical team meetings to ensure progress and address any questions or challenges regarding projects.
Project Retrospective Facilitation: Facilitate & write project retrospectives at the end of the project to improve future engagements.

6. Information Security and Data Protection Manager Functions

Team Leadership: Lead and develop a team consisting of a data protection executive and an information security officer.
Board Leadership: Set the agenda and chair the Information Security Board (ISB) and Data Protection Board (DPB).
Executive Updates: Provide regular updates on information security and data protection matters at Executive forums.
Roadmap Development: Develop, maintain, and deliver a roadmap of information security and data protection enhancements.
Best Practices Implementation: Ensure information security and data protection best practice is adopted across the organization through policies, procedures, coaching, training, and communicating widely.
Security Enhancements: Identify, recommend, and drive technological and procedural changes that mature the information security and data protection landscape within Buzz.
Breach Management: Act as the responsible owner for managing attempted or actual information security breaches.
Legislative Monitoring: Proactively monitor changes to data protection legislation, communicating and managing changes as they apply to Buzz.
Provider Coordination: Engage, manage, and coordinate service providers of information security and data protection services/consultancy.
Expert Consultation: Act as the Subject Matter Expert on information security and data protection for Buzz’s projects and changes.
Privacy Assessments: Perform Privacy Impact Assessments on new products/services and ensure the completion of Data Protection Audits on business functions and key risk areas.

7. Data Protection Manager Job Description

Framework Development: Utilize expertise to help develop and implement a data protection framework aligned with ISO 27001 and global privacy laws to facilitate the goal of achieving accreditation with various privacy standards.
Repository Maintenance: Create and maintain the central repository of evidence for data protection compliance, aligned with the data protection framework.
Monitoring Tool Creation: Create a monitoring tool and privacy controls and continuously monitor compliance with the data protection framework across the business.
Risk Assessment Assistance: Help perform data protection risk assessments and privacy assessments/audits of new technologies, vendors, and processes.
SME Support: Support the Global Quality Systems and Information Technology teams by acting as SME of privacy engineering.
Risk Identification: Identify potential issues and risks in respect to the processing of personal data both within and across business functions and document fully in the risk register, work to address issues and risks listed in the risk register.
Stakeholder Collaboration: Work with stakeholders in relevant functions and departments across the business to ensure that Premier maintains its records of processing.
Quality Control Performance: Perform quality control on the records of processing from each department to ensure consistency and alignment with relevant business policies.
Data Governance Compliance: Drive compliance with data governance policy requirements to archive and destroy data at the end of the information lifecycle across the business.

8. Data Protection Manager Overview

Data Framework Management: Responsible for maintaining a secure framework for the management of clients' data and ensuring compliance with data protection legislation.
Policy Development Collaboration: Work in conjunction with various stakeholders within the business to ensure that appropriate policies and procedures are developed and implemented to maintain an effective control framework.
Business Continuity Maintenance: Maintain the business continuity and associated crisis management framework for the business.
Awareness Ensuring: Ensure that there is continuing awareness of its requirements and that testing is undertaken on a regular basis.
Performance Monitoring: Monitor and report on the performance of the Data Protection function, as well as any data protection projects/actions/issues across the Group.
Due Diligence Involvement: Involvement in bids and tenders, as well as ongoing due diligence in respect of all suppliers and business partners.
Industry Knowledge Maintenance: Maintain knowledge of industry standards and best practice, as well as regulatory and legal requirements.
Regulatory Monitoring: Monitor and anticipate regulatory directions and the actions of the ICO and other regulators.
Data Protection Leadership: Provide leadership, management, and direction in relation to all areas of data protection, leading, motivating, and informing the leadership team in this respect.
Training Material Review: Regularly review/create training materials to be distributed to team members via LMS in relation to Information Security and GDPR.
GDPR Compliance Reviews: Regular reviews of compliance with all company policies relating to GDPR.

9. Data Protection Manager Details and Accountabilities

Function Development Assistance: Assist the Group Data Protection Officer, to whom this role reports, in driving and developing the data protection function within the business and establishing the Data Protection and Privacy Office across the Humn Group.
Global Advisory Provision: Provide pragmatic data protection and privacy advice to all Group entities across the globe with advisory work spanning Americas, EMEA, and the UK.
Privacy Oversight: Oversee and support business areas on a wide range of issues including the completion of Data Privacy Impact Assessments, Data Subject Access Requests, Data Subjects Rights Requests, Legitimate Interest Impact Assessments, Data Transfer Assessments, Retention Requirements, advice around marketing and related activities, and cookie compliance.
DSAR Management: Oversee responses to DSARs and other individual rights’ requests prior to release to ensure responses are in line with statutory and regulatory obligations and deadlines.
Vendor Due Diligence Participation: Participate in the review of third-party vendor due diligence requirements.
Representation on Committees: Represent the Data Protection and Privacy Office across advisory and functional committees such as the Information Governance Operations Group.
Breach Response Support: Support the business in relation to its breach response and mitigation procedures.
Policy Drafting Assistance: Aid the Group Data Protection Officer in drafting Policy, Procedure, and Guidance relevant to all Group Entities and Subsidiaries.
Authority Relationship Management: Manage relationships and responses with the relevant Data Protection Authority.
Commercial Assistance: Assist the Group Data Protection Officer in commercial activities such as any work related to merger and acquisition due diligence or partnership agreements.
Privacy Landscape Monitoring: Aid the Group Data Protection Officer in proactively monitoring developments across the global privacy landscape to advise the business on relevant changes.
Training Contribution: Provide and contribute to tailored data protection training either in person or online.
Deputy Role: Deputize for the Group Data Protection Officer.

10. Data Protection Manager Tasks

ISO Certification Maintenance: Maintain, develop, and support the extension where necessary of existing ISO certifications including ISO 9001, ISO 27001, and ISO 20252 within the EU and globally.
Internal Consultancy: Provide high-quality internal consultancy as a trusted advisor in relation to industry codes, quality, privacy, and data protection regulations.
Incident Triage: Able to assess, record, and triage global data protection and quality incidents to ensure these are dealt with appropriately and within required timeframes.
Compliance Logging Development: Develop and maintain centralized logging of compliance incidents to enable tracking and reporting of trends to promote continual improvement.
Data Request Management: Able to recognize and manage data subject requests in line with country legislation requirements.
Client Support: Ensure potential and existing clients are supported in relation to the provision of information to support new business and current client requests for information.
Training Programs Implementation: Ensure effective training and awareness programs are in place and their effectiveness measured through internal audit and other mechanisms.
Industry Compliance Monitoring: Stay abreast of industry trends and company product innovations and ensures continued compliance with Standards in a continually evolving business context.
Team Support: Support local teams in working to a consistent approach, building relationships, and sharing knowledge and expertise.
Project Compliance Support: Support internal projects and initiatives to ensure compliance with Standards.

11. Data Protection Manager Roles

Security Team Service: Serve on a distributed security and technology team responsible for establishing and maintaining data protection technical controls.
Policy Alignment: Align data protection policies and procedures with the corporate governance and risk management structure.
Risk Control Implementation: Work closely with security leadership, teammates, and stakeholders to evaluate and implement data protection controls that align with organizational risk posture and compliance requirements.
Technology Support: Support and maintain a wide range of data protection technologies, including but not limited to DLP, CASB, behavioral analytics, insider threat, data classification, data governance, and encryption.
Data Security Management: Secure and monitor data on-premises, in cloud infrastructure, and within applications required to support a dispersed remote workforce.
Rule Management: Manage and test business rules protecting data, as well as the use and handling of data assets.
Data Discovery Conduct: Conduct data discovery to locate data at risk, as well as validate existing data storage has not been altered.
Policy Documentation: Document data protection policies and exceptions, and periodically review with business units.
Improvement Recommendations: Make recommendations for improvements to ensure least privilege to data and rigorous security practices, without negatively impacting the end-user experience or leading to employees attempting to circumvent controls.
Tactical Execution: Execute tactical requests supporting the strategic vision for rigorous and scalable data protection controls.
Business Process Understanding: Maintain understanding of business processes to aid in managing enterprise data protection.

12. Data Protection Manager Additional Details

Policy Support: Support the maintenance of the group’s Data Protection Policy, setting principles for the management and protection of personal information in line with regulatory requirements and industry standard practice.
Standard Definition: Define, maintain, and embed a suite of relevant standards and guidance in support of the group’s Data Protection Policy.
Industry Engagement: Engage with relevant industry forums on an ongoing basis to continuously evaluate the Group’s data protection framework in the context of evolving regulations, regulatory guidance, case law, and industry best practice.
Knowledge Facilitation: Facilitate knowledge sharing and dissemination across business-aligned data protection specialists.
Training Program Assistance: Assist in the evolution of a consistent, targeted training and awareness program.
Stakeholder Advising: Advise stakeholders and Risk and Compliance personnel of data protection and privacy-related risks and issues.
Privacy Design Collaboration: Work closely with Information Security, Technology, and Customer Experience teams to ensure privacy by design concepts are embedded.
Query Triage: Triage and route inbound queries from third parties to relevant stakeholders.
Regulatory Support: Support the Group Head of Operational Risk and Compliance in engagement with regulatory authorities.
Document Review: Review and challenge data protection-related documents produced by businesses, including documents such as Data Protection Impact Assessments, Information Asset Registers, and Fair Processing Notices.

13. Data Protection Manager Essential Functions

Regulatory Notification Management: Responsible for the efficacy of notifications to the regulator (ICO), privacy notices, data subject rights, privacy impact assessments, privacy audits, and subject access requests, ensuring that they are responded to within the timescales.
Second Line Monitoring: Responsible for second-line monitoring of data and information protection.
DPO Deputy: Deputises for the Company Data Protection Officer.
Information Protection Oversight: Oversight and steering of information protection and data protection requirements required by the businesses and monitoring of data protection compliant delivery.
Data Protection Management: Manages and oversees data protection risks, data protection policies and procedures, training, communication, and company awareness for BMW Financial Services UK and Ireland and Alphabet GB Limited.
Compliance Advising: Advise Risk Assurance and Compliance Monitoring personnel on data protection-related subject matter, providing both general subject matter overviews and specific advice regarding individual reviews.
Risk Escalation: Escalate data protection risks and issues to the Data Protection Officer and via challenge of business representation of their data protection-related risks at their Risk and Compliance Committees.
Management Information Definition: Define and regularly produce Group-level data protection-related management information.
Executive Reporting: Prepare standard and ad hoc topical reports for executive-level audiences.
Governance Compliance Assurance: Ensure that all Governance and Compliance requirements are adhered to and all reporting and reviewing activities required by the Regulatory Bodies are carried out to the standards.

14. Data Protection Manager Role Purpose

Privacy Strategy Development: Develop privacy strategy, priorities, and plan (including timing, budget, and resourcing requirements).
Harmonization Collaboration: Work with senior management, business attorneys, legal team, and IT to ensure the organization maintains a consistent and harmonized approach to processing personal data.
Privacy Assessment Management: Manage the Privacy Assessment process and complete Data Protection Impact Assessments as required under applicable data protection laws.
Risk Identification: Work with the leadership team to regularly and pro-actively identify privacy risks and issues and ensure appropriate steps to mitigate risks are in place and timely remediation of issues.
Data Transfer Compliance: Ensure any transfers of personal data comply with all applicable laws.
Privacy Training: Train employees and prepare company communications on company privacy policies, data handling practices and procedures, and legal obligations.
DPO Service: Serve as Data Protection Officer in certain jurisdictions or liaise with local country Data Protection Officers.
Technical Solutions Oversight: Work with IT and management to ensure appropriate technical solutions are in place to protect personal data.
Policy Inquiry Handling: Inquire and complain regarding Softline’s privacy policies in collaboration with Compliance, IT, Legal, and other internal and external groups as necessary, and consistent with internal investigation process and procedures.

15. Data Protection Manager General Responsibilities

Data Protection Leadership: Lead a Data Protection team to design, build, configure, troubleshoot, or administer assigned enterprise-wide Data Protection technology, services, and/or programs.
Resiliency Model Establishment: Establish BAU resiliency and continuous service improvement models.
Initiative Governance: Lead, drive, govern, and develop enterprise-wide Data Protection initiatives, programs, and/or services.
Scalable Model Development: Establish scalable and sustainable models designed to secure the bank’s data while enabling business.
Staff Development: Develop staff with deep bench strength, cross-train staff to ensure resiliency and promote internal mobility.
Learning Culture Support: Support and encourage a culture of continuous learning.
Organizational Culture Development: Develop and maintain a positive organizational culture, establish strong relationships with cross-organizational peers and executives.
Technology Implementation Leadership: Lead and direct teams/staff in evaluation, selection, and implementation of data protection technologies/services/programs.
Business Case Creation: Create a business case proposal, socialize the proposal and solicit stakeholder feedback to support final decisioning.
Communication Plan Coordination: Lead and direct staff to create and coordinate communication plans for impactful changes to Data Protection technologies/processes or services with business and technology partners.
Training Material Development: Create custom training classes/materials in support of Data Protection technologies/processes or services.