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In the private sector it appears more common for the "DPO" to sit either in IT or CoSec/Legal and to cover all of the ground including handling SARs.

In retail organisations, unique PD of customers may reside on a multiplicity of systems and other records.

In many organisations, employees' PD often resides in more places than are generally considered when searching.  For example, drivers' tachograph records are often overlooked.  In addition, there is the nightmare of email.

Where PD is not highly centralised, and SARs are not handled centrally, my observation indicate that there are serious risks of not locating data, and of missing the 40 day supply period (reducing to "one month" under GDPR).

On 12 Jan 2017, at 09:26, Cotterill, Steve <[log in to unmask]> wrote:

I would agree. I wouldn’t let anyone else deal with an SAR and if I get a pay increase I will give the first months increase to charity (so that will be £0.00).

 

Stephen Cotterill
Procurement & Technical Officer

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Derek O'Connor
Sent: 12 January 2017 09:15
To: [log in to unmask]
Subject: Re: [data-protection] GDPR Data Protection Officer

 

I would agree with Victoria, I don’t believe the DPO is going to be suddenly elevated much beyond where they sit now, I also don’t believe being designated the DPO is going to automatically result in any pay increase. Those of us who work in this field are already carrying out this role (to a greater or lesser extent) and in doing so are keeping their organisation out of trouble and off the radar of the regulator. The organisation will just expect that to carry on, won’t they?

 

Derek O'Connor

Rheolwr Llywodraethu Gwybodaeth / Information Governance Manager

Cyngor Bwrdeistef Sirol CONWY County Borough Council
E-Bost / E-Mail: [log in to unmask]

Ffon/Tel 01492 574016

 


 

 

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Dan Palmer-Dunk
Sent: 11 January 2017 14:46
To: [log in to unmask]
Subject: [data-protection] GDPR Data Protection Officer

 

Good afternoon all,

 

I have noticed that quite a few DPO position adverts – or at least related ones mentioning DPOs and GDPR - I’ve seen advertised over the last few months have included handling SARs in the role responsibilities.  In considering how this new role can fit into the organisation I wondered if anyone had any thoughts on whether this would be viewed as a conflict of interest for a DPO?

 

I am aware that a DPO can carry out other tasks in addition their DPO duties, but if a DPO is meant to be a significantly independent and quasi-auditorial role, and report to the ‘highest level of management’, who would monitor SAR compliance and conduct reviews, etc?

 

Your views would be very welcome.

 

All the best,

 

 

Dan Palmer-Dunk

Information Compliance Officer

University of Hull

 




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