Hmm. Data protection officer. Another unnecessary enterprise IT role created to add to the anxiety of the CEO? Not exactly.
More about the need for a data protection officer
We’re literally days away from the revolutionary age of the European Union’s General Data Protection Regulation implementation. For almost every enterprise that sells to EU residents, the post-GDPR era will be challenging as they try to comply with the rules. GDPR calls for major changes in data processes, right from acquiring and storing data to processing and transmitting it among different applications.
This requires tremendous oversight, tight execution control, and robust review mechanisms. Also, to continue to ensure compliance with GDPR, companies need to stay abreast of the absolute latest data protection mechanisms, tools, and technologies.
Since these functions are too nuanced, demanding, and crucial to be performed by a CIO or CDO, organizations are becoming open to the idea of having a dedicated data protection officer in place.
Hiring a data protection officer, of course, will mean bigger costs for your business. So, the hiring decision isn’t exactly easy. Here are some insights to help you make the right decisions.
Ask — Do we need a data protection officer by law?
Yes, GDPR calls out organizations to appoint a dedicated data protection officer, depending on the volume of data they have pertaining to EU citizens. Public organizations also need to appoint a DPO.
This is probably a good time to introduce the data protection officer’s key responsibility. GDPR describes the DPO as a dedicated security professional entrusted with the responsibility of ensuring the organization’s compliance with the rules it lays out. As a decision maker, you need to think — even if we don’t store a lot of data of EU citizens today, will it be the same tomorrow too?
Note: If your business operates in any of these industries, chances are you need a DPO as mandated by law (because of the prominence of data in your business operations) — SaaS business, digital marketing, analytics, data mining, social media platforms, health-care, and education, to name a few.
Key responsibilities of a data protection officer
Your data protection officer is responsible for a wide array of data-safety procedures:
- Ensuring that the company, as well as these days third parties, are cognizant of the requirements of GDPR.
- Facilitating training for all relevant users of data to make them understand compliance requirements.
- Determining the impact of the rules laid out by GDPR.
- Serving as an impartial intermediary between the regulators and the organization.
- Developing data protection processes and policies, and documenting and representing them in a manner such that all stakeholders can understand them.
- Carrying out privacy impact analysis for any proposed alterations in processes.
- Taking complete ownership of audits and assessments cutting across data privacy and protection concerns.
Constructing the DPO persona for your enterprise
A person could be the perfect data protection officer for a health-care organization because of specialized experience in the field, but might not be a good fit for an e-commerce big player. That’s why it’s important for the hiring team to first build a persona for the data protection officer, based on these factors:
- The extent to which GDPR rules apply to them.
- The current and near-term data strategy of the organization.
- The most coveted and relevant data privacy, cybersecurity, and IT security certifications in your industry or geography.
- The combined complexity of your IT infrastructure, HR systems, and existing data practices.
- Whether or not you’d prefer the DPO to also be an attorney.
All these factors, mostly internal, go a long way in enabling organizations to truly build a representative persona of an individual who’d be able to fill the role of a DPO.
Key skills that a DPO needs to possess
Apart from your organization’s unique requirements, the DPO needs to bring a few essential skills to the table. Some of these are:
- Management experience and expertise in cybersecurity.
- Superb communication skills, because the DPO will need to interact with all levels of enterprise employees.
- Expertise in governance, risk management, and compliance.
- Basic appreciation of technologies relevant to data protection.
- Strong grasp of legal aspects of information management.
Other crucial aspects of hiring a DPO
For a small or medium-sized business, the temptation to promote an employee to the role of a DPO may be too good to resist. However, the decision comes with long-term legal and financial implications. So, take the bitter pill today for a better tomorrow. There’s a lot on a DPO’s plate. If your organization already has a dedicated professional entrusted with data security in general, probably there’s merit in the idea of appointing him or her as DPO.
Also, we’d recommend keeping aside some budget to upgrade the knowledge of your DPO via training programs. Make sure you budget the financing of these trainings.
Another key aspect of hiring a DPO is to understand their expectations from the enterprise’s C-suite officers and departments leaders. Also, understand as to what kind of tools the DPO will require to establish complete visibility of the data entering the organization’s IT ecosystem and leaving it. Invariably, you’ll need to use data protection tools to ensure GDPR compliance. You might as well do so in consultation with the DPO who’s going to use them every day.
It’s also sensible to talk in depth about a few important aspects of data protection with your potential DPO candidates. These include:
- Their experience in cybersecurity investigations.
- Their mechanisms to keep themselves updated about changes in regulatory and legal frameworks related to enterprise data.
- Experience in EU data protection laws.
They’re calling data the new oil. Liquid gold or not, the value of data makes the comparison justifiable. Expert and intelligent management of data will bring you tremendous financial success, and carelessness could be the undoing of your business. Good luck with your data protection officer hunt.
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