WHAT DOES A DATA PROTECTION OFFICER DO?

Published: October 8, 2024 - The Data Protection Officer supports the business by delivering timely legal and compliance advice and updating the internal policies and procedures framework. This role includes developing and conducting training and awareness programs across the group, advising on data protection issues such as data subject requests and privacy impact assessments, and maintaining up-to-date notifications with the Information Commissioner. Additionally, the position plays a critical role in fostering the sharing of knowledge and best practices and leading relevant data protection projects to ensure organizational compliance and security.

A Review of Professional Skills and Functions for Data Protection Officer

1. Senior Data Protection Officer Duties

  • Communication: Acting as the first point of contact for supervisory authorities, employees, shareholders, clients, and data subjects on data privacy-related questions
  • Assessment: Initiating and participating in Privacy Impact Assessments
  • Audit Response: Responding to audit requests from clients or shareholders
  • Process Design: Designing, implementing, and monitoring processes to ensure data privacy compliance
  • Training: Training employees (onboarding, yearly refresher, and role-specific training) on data protection
  • Monitoring: Monitoring the privacy mailbox for queries arising in relation to data privacy
  • Analysis: Collecting information to identify processing activities and analyzing the compliance of such processing activities
  • Negotiation: Reviewing and monitoring data processing agreements and negotiating the agreements with service providers and clients
  • Relationship Management: Managing the relationship with external legal counsel where local legal support is required
  • Documentation: Maintaining documentation prescribed by privacy laws
  • Legal Compliance: Regularly monitoring compliance with applicable laws (particularly the GDPR)
  • Project Leadership: Pursuing and leading various cross-departmental projects independently until completion
  • Process Improvement: Implementing, maintaining, and continuously improving data protection management processes across the group, to ensure that the organization respects all applicable data privacy laws.

2. Data Protection Officer Details

  • Regional Compliance: Be familiar and responsible for Asia’s data protection requirements and the Bank’s data protection policy
  • Internal Monitoring: Monitor compliance and data practices internally to ensure that the business and its functions comply with the respective DP requirements
  • Gap Analysis: Perform gap analysis against respective DP requirements
  • Policy Development: Work closely with departments (Information Security, Legal, and Compliance) to develop policies, requirements, and manuals applicable to the business and in compliance with the respective DP requirements
  • Compliance Review: Work with key internal stakeholders in the review of projects and contracts to ensure compliance with respective data privacy laws and, where necessary, advise on privacy impact assessments
  • Legal Monitoring: Monitor for changes or updates to the respective DP law and make recommendations. Be the single point of contact for all DP-related matters
  • Reporting: Contribute to the management security reports
  • Training: Develop and deliver privacy training to various business functions
  • Auditing: Coordinate and conduct data privacy audits.

3. Data Protection Officer Responsibilities

  • Advisory: Inform and advise the business and its employees of their obligations under the Act and other data protection legislation.
  • Compliance Monitoring: Monitor company compliance with the Act, other data protection legislation, and its data protection policies and procedures, including conducting internal and supplier reviews, assigning monitoring responsibilities, and reporting on outcomes of monitoring.
  • Training: Conduct awareness-raising activities and train employees on their obligations under data protection legislation and data protection policies and standards.
  • Assessment Advice: Monitor the performance of, and provide advice on, data protection impact assessments.
  • Regulatory Liaison: Cooperate with and act as the point of contact for data protection regulators.
  • Policy Support: Support the business by establishing and maintaining data protection policies, procedures, and compliance and enforcement structures.
  • Query Handling: Contact point for data protection queries from data subjects (customers, employees, and clients).
  • Innovative Development: Contribute to efforts to develop compliant, scalable, and innovative approaches to obtaining, managing, and analyzing data.
  • Legislative Awareness: Keep abreast of legislative changes, official guidance, and case histories that may influence the organization’s approach to data protection.
  • Internal Liaison: Liaise with the internal research ethics group and other relevant bodies.

4. Data Protection Officer Job Summary

  • Regulatory Guidance: Provides advice and guidance to the organization and its employees on the requirements of the GDPR, DPA, and other relevant international data protection legislation.
  • Compliance Monitoring: Monitors the organization’s compliance and briefs the Operations Director on areas of concern.
  • Research Support: Provides advice and support to researchers when developing data protection aspects of proposals for new projects.
  • Material Drafting Support: Provides advice and support to researchers when drafting data protection materials to support data collection.
  • Assessment Support: Provides advice and support for those drafting Data Protection Impact Assessments.
  • Contractual Support: Supports Legal Counsel in reviewing data sharing agreements and data protection schedules for contracts.
  • Regulatory Liaison: Acts as the point of contact for data subjects and for cooperating and consulting with relevant national supervisory authorities.
  • Training Leadership: Leads on organizational training and awareness-raising activities for data protection issues.
  • Resource Management: Creates and maintains centralized resources and templates for use in research projects.
  • Template Customization: Supports researchers in tailoring templates to meet data protection requirements for specific processing activities.
  • International Guidance: Guides colleagues from other jurisdictions on the processing of data from European data subjects.

5. Data Protection Officer Accountabilities

  • System Enhancement: Take over and enhance a strong, efficient, and sustainable global data privacy system.
  • Regulatory Assessment: Assess the applicability and requirements of relevant regulations for German, European, and global operations.
  • Strategy Advising: Act as an advisor to the Executive Board and management on all matters regarding data privacy strategy and execution.
  • Policy Collaboration: Work with Legal, Security, and Compliance Teams from multiple international markets to assess, maintain, and update data privacy policies and procedures for German operation and across the N26 group.
  • Risk Management: Increase effectiveness and efficiency while at the same time minimizing risk and participating in the design of customer-oriented and efficient products and services.
  • Regulatory Liaison: Act as a point of contact for regulatory reviews, coordinate information request responses, arrange meetings and briefings with the regulator, and address follow-up actions.
  • Auditor Relations: Manage ongoing relationships with auditors and regulators.
  • Training: Instruct group-wide employees in data privacy best practices.
  • Compliance Coordination: Engage with legal and compliance teams to ensure consistency in regulatory interpretation.
  • Executive Reporting: Provide updates to executive management, stakeholders, and operations teams on regulatory and audit developments.
  • System Maintenance: Maintain and update the data privacy management system together with the team.

6. Data Protection Officer Functions

  • Expertise Maintenance: Maintain expert knowledge of data protection law and practices, as well as other professional qualities, to ensure the company complies with the requirements of the EU GDPR and relevant UK data protection law(s) and regulations.
  • Documentation Management: Ensure that documentation to demonstrate compliance with the GDPR, such as policies and procedures, is kept up to date.
  • Staff Advising: Inform and advise all members of staff on their obligation to adhere to the EU GDPR and UK law(s) when dealing with personal data.
  • Compliance Monitoring: Monitor compliance with the EU GDPR and UK law(s).
  • DPIA Advising: Advise and inform on the data protection impact assessment (DPIA), including monitoring the performance of DPIAs.
  • Authority Liaison: Be the point of contact for the supervisory authority on issues relating to the processing of personal data, and consult with the supervisory authority, where necessary, on any other personal data matters.
  • Policy Development: Contribute to the development and maintenance of all company data protection policies, procedures, and processes in relation to the protection of personal data.
  • Management Advising: Advise management on the allocation of responsibilities internally to support ongoing compliance with the GDPR and UK law(s).
  • Training Management: Ensure training and awareness are available and delivered to all members of staff involved in processing operations relating to personal data.

7. Data Protection Officer Overview

  • Compliance Auditing: Regularly monitor compliance with the EU GDPR and UK data protection law(s) by conducting audits of processes relating to personal data, and report to the Leadership Team.
  • Data Subject Liaison: Be the point of contact for data subjects with regard to the processing of their personal data.
  • Policy Monitoring: Monitor compliance with the Data Protection Policy and develop/advise on procedures for effective security.
  • Management Advising: Advise senior management on the allocation of information security responsibilities.
  • Incident Reporting Development: Develop/advise on formal procedures for reporting incidents (EU GDPR and information security-related) and investigations under Articles 33 and 34 of the GDPR.
  • Business Continuity Contribution: Contribute to the business continuity and disaster recovery planning process.
  • Record Safeguarding: Advise on and monitor the safeguarding of organizational record management.
  • Security Appraisal: Review and appraise the soundness, adequacy, and application of security and other controls for the protection of data.
  • Control Testing: Identify and test the controls and, where appropriate, suggest additional controls, which may be established to maintain the confidentiality, integrity, and availability of personal data.

8. Data Protection Officer Tasks

  • Compliance Leadership: Acting as the focal point for all aspects of the firm’s compliance with the Act and related legislation, specific activities include:
  • Advisory: Informing and advising the firm with respect to its obligations under data protection law, as they impact the firm’s activities in general and/or specific functions across all service lines and business units.
  • Compliance Monitoring: Monitoring the firm’s compliance with data protection law and the EY Global Privacy Framework (notably EY’s Binding Corporate Rules), including the assignment of responsibilities, awareness-raising, and training of staff, and conducting and/or arranging for internal audits.
  • DPIA Oversight: Overseeing the firm’s Data Protection Impact Assessment process for the UKI and, when required under Article 35 GDPR, advising on high-risk DPIAs.
  • Regulatory Cooperation: Working and cooperating with supervisory authority, the Information Commissioner and serving as the contact point for the ICO on issues relating to the processing of personal data.
  • Data Subject Requests: Ensuring that requests from data subjects are dealt with promptly and in compliance with data protection law and being available to respond to inquiries from data subjects on issues relating to data protection practices and data subjects’ rights.
  • Incident Management: Responsibility for managing the firm’s data incident process, associated risk assessments, and advising the business on an appropriate course of action, including assessing whether the data breach must be notified to the ICO and/or data subjects.
  • Record Keeping: Keeping up to date the firm’s record of processing, as required by Article 30 of the GDPR.
  • Reporting: Providing an annual report and compliance return for local and regional leadership respectively.
  • Legal Liaison: Liaising with Legal Counsel to ensure contracts with clients and third parties protect the firm.
  • Privacy Response: Responding to all privacy/confidentiality matters related to the EY privacy framework asked by external regulators, auditors, and clients.

9. Data Protection Officer Roles

  • DPO Leadership: Act as Group Data Protection Officer (DPO) and help the business in complying with all relevant DP legislation.
  • Legal Support: Support the business via the prompt delivery of legal and compliance advice.
  • Compliance Assurance: Ensure the firm’s compliance with applicable privacy legislation, currently the EU General Data Protection Regulation.
  • Policy Development: Draft and update internal policies and procedures framework.
  • Training Delivery: Deliver training and awareness across the Group.
  • Management Advice: Provide advice to management on data protection matters.
  • Issue Advising: Advise on data protection issues such as data subject requests, potential data incidents, and privacy impact assessments.
  • Program Maintenance: Maintain the general data protection web-based training program within the firm and deliver other ad hoc awareness and in-depth training.
  • Compliance Maintenance: Ensure that the firm’s notifications to the Information Commissioner are maintained and up to date and accurate.
  • Knowledge Sharing: Support the sharing of knowledge and best practice.
  • Project Contribution: Contribute to and/or lead other relevant data protection projects.

10. Data Protection Officer Additional Details

  • Framework Development: Develop and maintain a framework for managing personal data.
  • Advisory Services: Continuously inform and advise on activities related to personal data issues, including advising on data protection impact assessments.
  • Compliance Auditing: Monitor compliance with relevant legislation by conducting regular audits within the framework of the General Data Protection Regulation (GDPR) and other relevant legislation.
  • Risk Analysis: Conduct risk analyses within the framework of GDPR and the Law of Electronic Communications (Lag om elektronisk kommunikation).
  • Regulatory Monitoring: Monitor changes in regulations and communicate these to the business.
  • Training Implementation: Create and implement training within the framework of GDPR and other relevant legislation.
  • Authority Liaison: Act as a contact person between Tele2 Sweden and relevant authorities (e.g., IMY and PTS).
  • External Representation: Represent Tele2 in external contexts related to data protection and other relevant areas.
  • Privacy Leadership: Be a central figure when it comes to internal privacy-related issues and challenges.
Relevant Information
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