Data Protection Officer (DPO)

The Data Protection Officer (DPO) is a key governance role established by GDPR. The DPO acts as an independent advisor within the organization, responsible for monitoring compliance with data protection regulations, advising on data protection impact assessments, cooperating with supervisory authorities, and serving as the contact point for data subjects.

GDPR mandates DPO appointment for public authorities, organizations whose core activities require regular and systematic monitoring of data subjects at scale, and organizations processing special categories of personal data at scale. In Germany, the BDSG (Federal Data Protection Act) extends this requirement to organizations with 20 or more employees regularly engaged in automated personal data processing.

The DPO must have expert knowledge of data protection law and practices, must be independent (cannot receive instructions regarding the exercise of their tasks), and must report directly to the highest management level. Organizations can appoint an internal DPO or engage an external DPO service.