I 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 co

I 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.