Interesting!
My reading is that the DPO must report to the highest decision making
authority in the organisation (CEO, Board of Trustees, whatever). I
understand that the Germans wanted the DPO to be able to report to the CEO
in order to ensure that s/he could not deny knowledge of any problems and
could be fully accountable.
This does not mean that the DPO is line managed by the CEO. The DPO can be
matrix managed where for most elements they have whatever line manager they
have, but when it comes to access to the CEO there must be no intermediary
so that there is total access allowing total accountability.
A typical configuration in some organisations is that IG managers are not
line managed by the SIRO but they have a relationship where there is a
monthly or fortnightly meeting and the IG manager acts on the delegated
authority of the SIRO. The IG Manager does not need to go through a chain
to reach the SIRO. This is similar, but the authority is higher (assuming
your CEO is not your SIRO).
Bilal Ghafoor
Information Governance Consultant
Bilal Ghafoor
@foikid
07926113401
On 12 January 2017 at 11:33, Dan Palmer-Dunk <[log in to unmask]>
wrote:
> Thank you all for your responses,
>
>
>
> I tend to agree that the GDPR will require the appointed DPO to report to
> an executive member as their line manager, although it seems as though
> differences in organisational structures mean this will have different
> implications (some will need no change, others might require a new role,
> which I think we will).
>
>
>
> I also think that (at least for now) I will suggest SARs being handled by
> the DPO – although we don’t have a large team dealing with info governance
> here.
>
>
>
> The guidance from the A29WP released before Christmas could have been a
> bit clearer!
>
>
>
> Thanks again,
>
>
>
>
>
>
>
> *Dan Palmer-Dunk*
>
> Information Compliance Officer
>
> University of Hull
>
>
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