Building a privacy office: Key strategies for EU/UK compliance

Maintaining GDPR compliance in the UK and EU shouldn’t be approached as merely a tick box exercise. In the same way financial accountabilityPerhaps the most important GDPR principle, which requires controllers to take responsibility for complying with the GDPR and, document their compliance. or cybersecurity is embedded within the structure of an organisation, managing personal dataInformation which relates to an identified or identifiable natural person. responsibly is a fundamental part of doing business. When privacy is woven into your organisation’s culture, it doesn’t just help maintain legal compliance, it strengthens trust, reduces risk, and supports long-term growth.  

A dedicated privacy team is no longer optional but a strategic necessityThe purpose of the personal data processing activity must not be able to be achieved by a less intrusive method.. With the right structure, data protection becomes an ongoing proactive strategy. But how do you build a privacy office that works?  

In this blog, we cover the key strategies for building a strong privacy office, defining the core roles and responsibilities. We also provide an overview of data protection compliance frameworks that support both compliance and business growth. From appointing a Chief Privacy Officer (CPO) to establishing clear policies, we’ll outline the steps to structuring a data protection compliance frameworkA series of policies, procedures, actions plans etc. detailing an organisation's compliance with any relevant laws, Codes of Practice etc. that meets regulatory requirements and supports your long-term success. 

Why privacy governance is essential for EU/UK compliance

Privacy governance refers to the framework of policies, procedures, and practices that organisations implement to manage personal data responsibly. 

A strong privacy governance programme helps organisations:

• Identify and mitigate risks by implementing Data Protection Impact Assessments (DPIAs) and regular compliance audits
• Ensure accountability through clear policies and documented processes
• Build customer trust by demonstrating transparency in personal data collection, processing, and retentionIn data protection terms, a defined period of time for which information assets are to be kept. practices
• Maintain compliance with data protection regulations, such as the GDPR 

Privacy governance is critical for ensuring compliance with the GDPR, which applies to all EU and UK organisations that processA series of actions or steps taken in order to achieve a particular end. the personal data of EU/UK individuals. Its extra-territorial scope also requires businesses worldwide to comply if they offer goods or services to individuals in the EU/UK or monitors their behaviour. Non-compliance can result in significant fines, reputational damage, and operational disruptions, making robust personal data management practicesThe systematic and compliant handling of personal data throughout its lifecycle. This includes processes for data collection, storage, security and governance, ensuring adherence to data protection laws.  essential. 

How to structure your privacy office – the core roles and responsibilities

The composition of a privacy office will vary depending on an organisation’s size and industry, and regulatory environment. Different jurisdictions may also use varying role titles based on legal requirements. For example, the EU mandates a Data Protection Officer (DPO) in certain cases, whereas in the US, Canada, and other regions, organisations typically use titles like Chief Privacy Officer (CPO) or Privacy Counsel instead. 

Despite these naming differences, the core responsibilities remain similar, as detailed below:

Data Protection Officer (DPO), Chief Privacy Officer (CPO), Group Data Protection Officer (GDPO)

A Data Protection Officer (DPO), also known as a Chief Privacy Officer or Group Data Protection Officer, is the backbone of a strong privacy office, setting the vision and leading the entire privacy team. The DPO advises senior management on the data protection aspects of business strategies, including the compliance requirements when entering a new market. They also keep the organisation informed about regulatory changes to ensure ongoing compliance

Key responsibilities include: 

• Informing and advising the organisation of their responsibilities under data protection laws 
• Conducting training to inform employees of their data protection obligations 
• Providing guidance on privacy policiesA term used to describe a series of documents (such as Privacy Notices and Registers of Processing Activities) which are used to account and explain to data subjects how their data is to be processed (most commonly associated with website ‘privacy policies’). and procedures 
• Monitoring the organisation’s compliance through conducting audits and other reviews 
• Advising on Data Protection Impact Assessments (DPIAs), which identify risks and mitigation measures 
• Liaising and cooperating with Supervisory Authorities, as required 

Data Protection Managers (DPMs), Data Privacy Specialists

Data Protection Managers (also called Data Privacy Specialists) support the DPO (CPO or GDPO) with the daily  operations of the privacy office. Their tasks may include developing and updating privacy policies, resolving ad hoc queries, managing personal data breach responses, and ensuring third-party vendors comply with data protection requirements. They may also advise on specific areas of data protection, such as international transfers or handling the full life cycle of any Data SubjectAn individual who can be identified or is identifiable from data. Access Requests (DSARs).  

IT Security Specialist  

An IT Security Specialist ensures effective collaboration between the privacy and IT teams. They implement security measures to safeguard personal data, conduct regular vulnerability tests to expose potential threats, and respond to data security incidents.  

Legal Counsel 

The Legal Counsel ensures that the organisation’s data protection practices comply with applicable laws. They provide guidance on legal matters, advise on how data protection laws interplay with and relate to other applicable legislation, and may review and draft data protection clauses in third-party contracts.   

Data Protection Representatives 

Depending on its location and activities, a business may need to appoint external Data Protection Representatives, such as EU or UK GDPRThe UK General Data Protection Regulation. Before leaving the EU, the UK transposed the GDPR into UK law through the Data Protection Act 2018. This became the UK GDPR on 1st January 2021 when the UK formally exited the EU. Representatives, to handle enquiries from data subjects and supervisory authorities. GDPR Representative: Do you need one?

Privacy governance framework 

An effective privacy governance framework should include the following elements: 

Please note: This list is not exhaustive. Depending on the specific needs and context of your organisation, additional elements may be required to ensure a comprehensive privacy governance framework. It is important to assess your business’s needs and consult with privacy professionals to maintain maximum compliance. 

Challenges of building a privacy office

• Finding experienced individuals – It’s difficult to recruit professionals with the right expertise in privacy law, data protection, and regulatory compliance

• High costs – Hiring full-time specialists for every role in a privacy office can be expensive, especially for smaller organisations

• Keeping pace with regulation changes – Data protection regulations are constantly evolving, making it difficult to stay up to date and ensure ongoing compliance

• Managing fluctuating work volumes – Privacy offices are often tasked with numerous, complex responsibilities, such as risk assessments, data subject rights management, and incident responses; the team may manage under normal condition, but there may be times when additional resources are needed to handle surges in demand

• Lack of internal resources – Many companies don’t have the necessary internal resources or infrastructure to properly support a fully functioning privacy office, however, you can overcome these challenges by hiring a fractional privacy expert or consulting external privacy professionals to provide guidance and support as needed

Solutions for building a strong privacy office

Building an effective privacy office requires the right expertise, resources and strategies to manage compliance and future-proof the organisation for regulatory changes. Here are the solutions many organisations use to ensure

• Hire fractional privacy experts to provide ongoing and specialised expertise without the cost of a full-time employee
• Engage data protection consultants for specific projects and fluctuating workloads
• Invest in training and development to upskill existing team members and help to bridge data protection knowledge gaps

Summary: Steps for building an effective privacy office

1. 1. Define team structure –  Identify key roles based on organisational needs. Consider using a RACI matrixA project management tool used to define roles and responsibilities. RACI stands for Responsible, Accountable, Consulted, and Informed. The key principle of the RACI model is that each task should have only one person assigned as accountable. to map responsibilities across various roles
      
   2. Appoint key roles – Ensure responsibilities are clearly assigned
   3. Establish governance frameworks – Implement clear policies, risk assessments and compliance mechanisms
   4. Embed privacy into business operations – Conduct regular training and awareness exercises, and ensure ongoing monitoring

If your organisation needs expert privacy support, The DPO Centre offers outsourced privacy office services, including CPOs, DPOs, DPSOs, EU and UK Representatives and compliance expertise.

Learn how we can help strengthen your privacy team – contact us for more details. 

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In case you missed it… 

• Understanding GDPR territorial scope: Essential compliance guide
• Compliance with the AI Act Part 4: Essential strategies 
• What is a DPA and why do you need one? 

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