Hi Phil,
Is that not just reflecting the option some organisations have to appoint a DPO 'on the basis of a service contract' (art 37(6))?
As the A29WP guidance says, 'This means that the DPO can be external, and in this case, his/her function can be exercised based on a service contract concluded with an individual or an organisation'.
That's how I read the first question, anyway.
Regards,
Peter
Peter Dinsdale
Data Protection Consultant
Perfect Image /
T: 0191 238 0111
www.perfect-image.co.uk
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-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Phil Bradshaw
Sent: 30 May 2018 09:49
To: [log in to unmask]
Subject: Re: [data-protection] Registering your DPO
In addition to the technical error the process makes no sense.
First page asks if your DPO is an individual or an organisation. Almost certainly they mean are you registering for an individual or an organisation which is not the same thing.
If you say "an individual" it doesn't enquire whether the DPO is DPO for an organisation - which confirms the first question is flawed. But if you select "organisation" it doesn't ask for the name of the DPO! So apart form the scripting error the process is badly designed from the outset.
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