EDPB report on areas of improvement for the position of DPOs in EU
A coordinated investigation by EU supervisory authorities into the role of DPOs
February 05, 2024
EDPB report on areas of improvement for the position of DPOs in EUA coordinated investigation by EU supervisory authorities into the role of DPOsFebruary 05, 2024 Why should I read this?By way of background information, this report is published as a result of a year long initiative from various supervisory authorities (“SAs”). SAs have been collecting information on the position of data protection officers (“DPOs”) across their jurisdictions through questionnaires, followed by an analysis of all the gathered findings by the European Data Protection Board (EDPB). This EDPB report is a combination of these coordinated actions across 25 jurisdictions and will impact companies that require the appointment of a DPO. This report above all provides a list of 7 recommendations that companies and their DPOs can take into account to address issues identified during the coordinated investigation phase. These findings from national supervisory authorities again emphasise the need to further strengthen and promote the role and importance of DPOs. What does the report recommend?The executive summary of the report identifies 7 areas of concern plus examples of recommendations for each problem area as set out below. Companies, DPOs and SAs should use such recommendations to address these challenges going forward, as they are now considered “best practise”.
What else do I need to know about the role of DPOs?Due to new EU legislation in the digital field, such as the AI Act and Digital Services Act, DPOs are being tasked with new roles related to e.g. AI, ethics and data governance. New roles may lead to challenges such as conflict of interests, insufficient available resources and inadequate expert knowledge and training of DPOs. It is vital for companies to consider the task and support of the DPO to ensure they can continue to provide the best added value. An alternative could be to (partially) outsource your DPO needs. Eversheds has a DPO as a Service offer in place for almost 4 years. Such a model is able to provide your company with the expert level necessary to navigate this evermore complicating landscape of (personal) data governance. On this report, it is also worth mentioning that there is no particular ranking in the focus areas and the report is lacking a comprehensive answer on how companies can measure/benchmark the role or position of the DPO within their organization. It will be interesting to see if such aspects will be addressed in the further development of the WP29 Guidelines on DPOs. Latest Insights
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