Cooperation with the External Data Protection Officer
How is practical cooperation with an external DPO structured?
Practical cooperation with an external DPO combines on-site presence with digital communication: Regular on-site appointments enable personal consultations, training and inspection of relevant company areas. Between these appointments, the DPO is available by phone, email and video conference for short-term consulting needs. A fixed internal contact person coordinates communication between DPO and specialist departments. Digital collaboration platforms facilitate document exchange and tracking of measures. This is supplemented by regular status reports and annual reports for continuous information of company management.
How is the external DPO integrated into operational processes?
The integration of the external DPO into operational processes is done through clear regulations and process integrations: They are systematically and early involved in all data protection-relevant projects and decisions, ideally already in the planning phase. For the IT department, checklists are created when the DPO should be consulted, e.g., for new software or system changes. The legal department or purchasing involves the DPO in contract design with data protection relevance. Additionally, regular reporting to management takes place, while internal communication channels such as intranet or newsletters regularly address data protection topics to ensure presence of the topic in everyday business.
What time commitment is typical for an external DPO?
The time commitment for an external DPO varies depending on company size, industry and complexity of data processing: In small companies with low risk potential, often 1-2 working days per month are sufficient. Medium-sized companies with more extensive processing typically require 2-4 days monthly. For larger companies or in particularly data protection-sensitive industries such as healthcare or financial services, the effort can increase to 5-10 days per month or more. During implementation phase or for special projects such as introducing new systems, time requirements increase temporarily. A customized package considers individual needs and can be flexibly adapted to changing requirements.
What information does the external DPO need for their work?
For effective work, the external DPO needs comprehensive information: Overview of organizational structure, business processes and IT landscape, access to records of processing activities and existing data protection documents as well as relevant contracts with service providers and customers. They must be informed about planned or ongoing projects with data protection relevance and receive insight into existing technical and organizational measures for data security. Information about occurred data protection incidents, requests from data subjects or supervisory authorities as well as company-specific policies and work instructions with data protection relevance are also important. An open information culture with transparent communication is crucial for successful cooperation.
How is the success of the external DPO's activity measured?
The success of the external DPO's activity is measured using various indicators: Quantitative metrics such as the number of training sessions conducted, processed requests from data subjects or reviewed processing procedures provide information about activities. Qualitative criteria include improvement of data protection compliance level, successful integration of data protection requirements into projects and processes as well as increased data protection awareness of employees. Concrete progress can be documented in data protection audits. Avoidance of data breaches and complaints as well as positive feedback from supervisory authorities are also important success indicators. Regular status meetings and annual reports document achieved improvements and define further goals.
How is cooperation with supervisory authorities structured?
Cooperation with supervisory authorities is an important part of DPO activities: As official contact person, the external DPO represents the company in data protection matters and serves as interface for authority inquiries. They support timely and complete response to information requests and prepare the company for regulatory inspections. For complaints from data subjects directed to the supervisory authority, they coordinate the company's statement. In case of notifiable data breaches, they handle communication with the authority and provide all necessary information. The DPO also informs about relevant publications and positions of supervisory authorities and considers these in their recommendations for continuous improvement of data protection compliance.
