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That'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-
by Matticus_Rex 8y ago
That'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.