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ARTICLE · 10 OCTOBER 2017

Expert Comment, Rob Corbet – Data Protection Ireland, Volume 10, Issue 5

Arthur Cox
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The countdown to GPDR commencement on 25th May 2018 continues and one of the most pressing questions concerning organisations is ‘who will be our Data Protection Officer (‘DPO')'?

IrelandPrivacy
Rob Corbet
Rob Corbet
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The countdown to GPDR commencement on 25th May 2018 continues and one of the most pressing questions concerning organisation is 'who will be our Data Officer ('DPO')'? The topic has sparked a lot of confusion so it's worth distilling the facts from the fiction so that informed decisions can be made.

Must I appoint a DPO?

Article 37(1) GDPR requires data controllers and processors to designate a DPO in any case where:

  • the processing is carried out by a public authority or body;
  • the 'core activities' of the controller/ processor consist of processing operations which 'require regular and systematic monitoring of data subjects on a large scale'; or
  • the core activities of the controller/ processor consist of processing on a large scale of 'special categories of data' or personal data relating to criminal convictions and offences.

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