In September, the UK Department for Digital, Media, Culture and Sport released a consultation document, entitled Data – A New Direction about the future of data protection law in the UK whereby it proposes significant changes to the existing UK data protection law.
CEDPO, the Confederation of European Data Protection Organisations, has made comments on one of the proposed changes, i.e., the one related to the position of the Data Protection Officer (DPO). The reform proposes to remove the requirement of appointment of a DPO and to replace it by the appointment of an individual in charge of running the privacy management program.
CEDPO believes that the reasons put forward do not justify the removal of the DPO and that this role should be maintained in the UK Data Protection Act as the DPO fosters a reasonable, practical, balanced, effective and expertise-based protection for personal data.
The CEDPO submission is available here.