← NDPA 2023 · Governance

s.32 — Designation of a Data Protection Officer

high dporoles-responsibilities

Requirement

A data controller of major importance shall designate a Data Protection Officer with expert knowledge of data protection law and practice, who may be an employee or engaged under a service contract. The DPO advises the controller and its staff, monitors compliance, and is the contact point for the Commission (s.32). Other organisations should record why they are not required to appoint one.

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
data protection officerdpoprivacy officer
Required element 2 — any one of
designat…appointcontactpublished
Supporting terms — specificity signals
section 32expert knowledgereports toindependentservice contractmajor importance

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.37 Designation of a data protection officer dpo roles-responsibilities
GDPR Art.38-39 Position and tasks of the data protection officer dpo roles-responsibilities
GDPR Art.26 Joint controllers roles-responsibilities
GDPR Art.27 EU representative for non-EU organisations roles-responsibilities
GDPR Art.29 Processing under the authority of the controller roles-responsibilities
SOC 2 CC1.3 Organisational structure and reporting lines roles-responsibilities
SOC 2 CC1.5 Accountability for control responsibilities roles-responsibilities
ISO 27001 A.5.2 Information security roles and responsibilities roles-responsibilities