DPO or NOT to DPO that is the question.
Daniel Broome
Fractional strategic HR directors | Adding commercial value | Helping businesses and people thrive | Proven results of business growth and transformation | Trusted people experts ?? peoplepuzzles.co.uk
Under the GDPR, you must appoint a DPO if:
you are a public authority or body (except for courts acting in their judicial capacity);
your core activities require large scale, regular and systematic monitoring of individuals (for example, online behaviour tracking); or
your core activities consist of large scale processing of special categories of data or data relating to criminal convictions and offences.
But what if you don't fall into one of the above or you don't at the moment ?
This is what the ICO say:
"Some organisations are required to appoint a DPO. A DPO’s tasks include advising you about the GDPR, monitoring compliance and training staff.Your DPO must report to your highest level of management, operate independently, and have adequate resources to carry out their tasks.Even if you’re not obliged to appoint a DPO, it is very important that you have sufficient staff, skills, and appropriate reporting structures in place to meet your obligations under the GDPR."
Still not sure ?
What does it say to your customers if you choose not to have a DPO?
What does it say to your employee's if you choose not to have a DPO?
What might be stopping you ? Cost ? Time ? Knowledge ?
Outsourcing this function is very similar to out sourcing your FD or CTO.
Find an organisation or individual who offers this service check out the experience of the Fractional DPO's they represent. Speak to the actual DPO they are offering you?
You need to make sure that you can work with each other, they are going to become an integral part of your Leadership team going forward, helping to shape your business and the processes underpinning it.
Once you have found a suitable partner how much time do you want them to spend working with you ?
Is it a day month? two days maybe some remote time on an adhoc basis alongside some set time in the office each month. Decide what your current need is but make sure that you have some flexibility built in as you may need to increase this level of support around an event or issue?
I guess it is an important decision and one you need to spend time making.
If you want to talk through your options then please give me a call....