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Data Protection Officer, Controller, and Processor: Overview

Data Protection Officer (DPO)

Role: The Data Protection Officer oversees GDPR compliance.

  • Requirement: Small organizations handling minimal data may not need to appoint a DPO.
  • Appointment Criteria: A DPO is necessary if:
    • You are a public authority.
    • You conduct large-scale systematic monitoring of individuals.
    • You process large-scale special categories of data.
  • Responsibilities:
    • Hold relevant qualifications and detailed GDPR knowledge.
    • Report to top management and be fully involved in data protection matters.
    • Cannot be penalized for carrying out their duties.

Data Controller

Definition: The entity determining the purposes and means of data processing.

  • Examples: Individuals, organizations, companies, agencies, or public authorities.

Data Processor

Definition: The entity processing personal data on behalf of the controller.

  • Examples: Individuals, organizations, companies, agencies, or public authorities.
  • Role: Processes data without decision-making authority.
  • Examples: Accountants handling payroll, online service providers like Salesforce.
  • Distinguishing Factor: Processors do not control or make decisions about the data they process.

Entities can fulfill both controller and processor roles, depending on the context.