Here it tends to be a bit of a mix. I mostly tend to try and direct the investigation by telling the business area what information I need and then let them go out and get it (otherwise you just don't get the relevant data back). That said, there are occasions when you have to do some investigating yourself to get to the bottom of things or check that the business areas report actually adds up.
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Darren Richards
Sent: 26 November 2019 14:50
To: [log in to unmask]
Subject: [data-protection] DPO Role in Breach
Hi everyone
Just wondering what everyone's position is on the role of the DPO in the event of a breach? Do you think they should be actively carrying out the "investigation" for the service area that had the breach or that they should focus solely on advising as appropriate in respect of what steps should be taken in regards of notification to ICO/subject if needed?
As an example I believe it should go like this: HR have a data breach and inform DPO. HR then carry out the investigation to find out what was breached, how it got breached and to put in place any appropriate mitigating actions. DPO may then ask some clarifying questions around the data and whether HR should do anything in respect of notifications (either to ICO, subject or both). HR then inform relevant parties if advised to do so and then the DPO is advised of the outcome of investigation and it is logged.
I feel our DPO spends too much time "investigating" himself and treading on the service areas own investigation, even to the point of contacting the people involved when the service area is also communicating with them causing unnecessary confusion.
So how much involved should the DPO get in when it comes to "investigations" of personal data breaches?
Hope that makes sense!
Thanks
Darren
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