Data Protection Officer

The Data Protection Officer (DPO) serves as the organization's internal expert on data protection compliance. The role was formalized by GDPR Articles 37-39, which define when a DPO must be appointed, their responsibilities, and their required level of independence.

A DPO's core responsibilities include informing and advising the organization about its data protection obligations, monitoring compliance with GDPR and internal data protection policies, providing advice on Data Protection Impact Assessments, cooperating with the supervisory authority, and acting as the contact point for data subjects exercising their rights.

Importantly, the DPO must operate independently within the organization. They cannot receive instructions about how to perform their tasks, cannot be dismissed or penalized for performing their duties, and must report directly to the highest level of management. For many small and mid-sized companies, especially SaaS startups, appointing a DPO is not legally required. However, designating someone with data protection responsibility — even without the formal DPO title — is considered good practice and is often expected by enterprise customers during vendor assessments.