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Smaller firms can add "compliance officer" or "privacy officer" to the list of job duties someone does. But yes bigger firms can more easily afford bigger compl
by supertrope 8y ago
Smaller firms can add "compliance officer" or "privacy officer" to the list of job duties someone does. But yes bigger firms can more easily afford bigger compliance/legal/auditing/lobbying departments.
- Matticus_Rex 8y agoThat's the thing, though -- it doesn't scale like that. If a 100-person company has a DPO, you can't have someone who spends 20% of their time as a DPO in a 20-person company, because just keeping up with what you need to know takes a large amount of time.
- Someone1234 8y agoNeither one needs a DPO. A DPO is a requirement for companies with 250 more more employees.
- Matticus_Rex 8y agoI was using it as a stand-in for privacy officer (and the argument is true in either case), since the WP guidance has indicated that in many cases in smaller companies, they're treating a role that looks like a DPO as a DPO. There's also significant vagueness around what it means to be a large-scale processor (which also triggers the DPO requirement), and recent guidance suggests that a lot of companies that thought they didn't need a "DPO" really do need a DPO.