I'm not seeing any interpretation being done here, but judge for yourself. Here is what the GDPR actually says (Art. 37 Designation of the data protection offic

I'm not seeing any interpretation being done here, but judge for yourself. Here is what the GDPR actually says (Art. 37 Designation of the data protection officer): > (1) The controller and the processor shall designate a data protection officer in any case where: > a) the processing is carried out by a public authority or body, except for courts acting in their judicial capacity; > b) the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or > c) the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 or personal data relating to criminal convictions and offences referred to in Article 10.