We are increasingly having conversations with clients who require ongoing support in relation to their GDPR compliance – ranging from those that must appoint a Data Protection Officer (DPO) under GDPR, to those that are not required to do so but do need general compliance advice. In response to this demand, we have launched a Virtual DPO product. Our Virtual DPO offering will assist clients that must appoint a DPO, as well as those who need more general compliance support. This can, of course, be tailored to their specific requirements.
What is the issue?
Under GDPR, certain organisations are required to appoint a Data Protection Officer (DPO). The DPO is a specialist role – the appointee must be able to act in a sufficiently independent manner, must be someone who is an expert in data protection, and must report to the highest management level. However, a DPO can be externally appointed.
Which organisations must appoint a DPO?
Aside from public authorities, an organisation must appoint a DPO where its core activities consist of regular and systematic monitoring of individuals on a large scale or processing on a large scale of special categories of data (health data, for example) or personal data relating to criminal convictions and offences. "Large scale" is not defined in GDPR, but we have some internal guidance on the issue, which we'd be happy to discuss with colleagues.
However, even if you are not required to appoint a DPO, you still need to make sure that there is appropriate resource within the organisation to meet their obligations under GDPR, and the Virtual DPO service can provide this resource where it is not available internally.
How can we help?
At Mishcon de Reya, we recognise that the DPO is a specialist role, requiring a complicated balance of skills and knowledge, and we know from discussions with clients that not all of them are able to meet this need in-house.
This is the reason we launched our Mishcon Virtual DPO service providing you with the support of a DPO equivalent, on terms tailored to your specific requirements. We will agree the right resource level for your needs and set a monthly cost to allow you budgeting transparency.
Please see the attached brochure for more information on the service and consider sharing with your clients and contacts.