The Role of the Data Protection Officer: A Cross-Industry Essential

The role of a Data Protection Officer (DPO) has evolved far beyond being a niche position confined to specific sectors; it has become an essential function across various industries. Regardless of the type of data handled—be it health records, customer details, financial information, or employee data—the core focus of a DPO revolves around safeguarding personal data. With data protection regulations like the General Data Protection Regulation (GDPR) in Europe and similar laws worldwide, organizations in diverse industries require DPOs to ensure compliance, manage risk, and protect individual privacy.The DPO’s main job is to ensure that personal information is managed securely and in compliance with data privacy regulations. This role is essential across all sectors handling individual personal data.

In this article, we’ll explore five key industries where the role of the DPO is critical and the responsibilities they undertake in each.

  1. Healthcare and Life Sciences

Due to the private and sensitive nature of patient information in healthcare, strict data security rules are needed. From hospitals to drug companies, businesses in this field deal with private health information like medical records, diagnoses, treatment plans, and insurance information. In the healthcare field, a DPO is very important to ensure that patient data is gathered, stored, and processed safely. This lowers the chances of data breaches, for the could otherwise damage patients’ privacy and trust.

Along with GDPR for businesses that work with or in the EU, a DPO in healthcare also makes sure that certain rules are followed, like the Health Insurance Portability and Accountability Act (HIPAA) in the US. As part of this role, they are expected to conduct regular assessments of data protection, handle requests from data subjects, and ascertain that third-party providers follow strict privacy rules.

  1. Finance and Banking

Banks, insurance companies, and investment firms handle a lot of sensitive personal and financial data. This makes the financial services industry extremely data-centric and intensive. Generally these entities are privy to data like account information, a history of transactions, credit scores, and information that can be used to identify a person. Since they deal with sensitive data, finance and banking companies are easy targets for cyberattacks, highlighting the importance of a DPO in this sector.

To make sure strong protections are in place, DPOs keep an eye on activities that process data, evaluate and reduce risks linked to third-party vendors, and work with cybersecurity teams. Since there is a big chance of identity theft and financial crime, the DPO is responsible for ensuring strict compliance with data privacy rules to facilitate customer trust and prevent sanctions due to non-compliance. This is important for keeping customers trusting the company and following the law.

  1. Aviation or Airline Industry

The airline business handles a lot of personal data, such as passengers’ names, travel histories, payment information, and even health data that could be seen as private. A Data Protection Officer (DPO) is needed to make sure that global data protection laws (like GDPR, CCPA, DPDP or even DIFC) are followed and that sensitive data is kept safe from being stolen. The DPO is also in charge of data privacy, managing the rights of data subjects, and making sure that the airline’s systems and partnerships with third parties follow strict data protection rules. This helps build trust and safety among passengers.

  1. Telecommunications

Every day, phone companies handle a huge amount of personal data, such as location data, call records and patterns of internet use. This information is very private and needs to be treated with great care. In the telecommunications business, a DPO makes sure that customer data is handled with utmost compliance and that customers’ privacy rights are respected.

The job includes keeping an eye on policies for data retention, making sure that data is only kept for as long as it needs to be, and responding to requests from people who have the right to view their data. As telecom services become more important, especially for digital contact and working from home, DPOs help businesses stay in line with privacy laws while keeping service quality and customer trust.

  1. Technology and IT Services

A lot of personal data is processed by software companies, IT service providers, and data analytics businesses in the technology industry. This data is spread out across many applications and platforms. Since these businesses may deal with user profiles, behavioural data, and personal information, data must be kept safe. DPOs in this field are in charge of making sure that activities related to collecting and processing data are in line with international data security laws.

DPOs in tech companies deal with a lot of complicated data-sharing agreements and sending data across borders all the time. They oversee the risks that come with working with third-party sellers, use privacy-by-design when making new products, and check that their data protection measures are up to date with global standards regularly. They play a key part in keeping data safe on cloud platforms, mobile apps, and Internet of Things (IoT) devices.

Privacy Laws & DPO Mandate

Here are five major privacy laws/acts and their specific clauses or articles that mandate the appointment of a Data Protection Officer (DPO) if an organisation processes individual personal data:

    • General Data Protection Regulation (GDPR) – Europe
      • Article 37: Article 37 of the GDPR indicates that an organisation must have a DPO if it (a) is a public authority, (b) does large-scale systematic tracking, or (c) handles large amounts of certain types of individual personal data.
    • Dubai International Financial Centre (DIFC) Data Protection Law (DPL 2020) – Dubai
      • Article 16: Under the DIFC DPL 2020, appointing a DPO is mandatory if the data processing involves (1) high-risk data processing activities, (2) regular and systematic monitoring of data subjects, or (3) large-scale processing of special categories of data. The DPO must have adequate independence to perform data protection responsibilities within the organization.
    • Personal Data Protection Act (PDPA) – Thailand
      • Section 41: The PDPA requires the appointment of a DPO if the organization processes personal data on a large scale, engages in systematic monitoring, or processes sensitive data.
    • Digital Personal Data Protection Act (DPDPA) – India
      • Section 10: Under the Digital Personal Data Protection Act (DPDPA) of India, it mandates to appointment of a Data Protection Officer (DPO). This section outlines the obligations of “Significant Data Fiduciaries,” entities that process large volumes of personal data or sensitive information.
    • Protection of Personal Information Act (POPIA) – South Africa
      • Section 55: POPIA mandates appointing an information officer (similar to a DPO) who ensures compliance with the Act and promotes awareness of data protection obligations among employees within the organization.
Why the DPO Role is Essential Across Industries

Despite variations in data types—from patient records in healthcare to shopping preferences in retail—the essence of the DPO’s role remains the same: to protect individual privacy rights and ensure compliance with data protection laws. A DPO’s role transcends industries because, at the core, it is not about the type of data but rather the responsibility of organizations to respect and protect personal data. With a DPO in place, companies can maintain customer trust, reduce risks of regulatory fines, and build a culture of data protection.

Conclusion

Regardless of the type of data processed, a DPO can excel in any industry when equipped with the skills to understand local privacy regulations, like GDPR in Europe or DPDP in India. By implementing a robust data privacy framework and ensuring compliance with legal standards, a skilled DPO safeguards personal data across diverse sectors. Their expertise allows them to adapt to various industry needs, bridging compliance requirements with effective data protection practices that build trust and security.

Tanin Chakraborty
Tanin Chakraborty
Senior Director & Global DPO
Biocon Biologics
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Disclaimer: The views expressed in this feature article are of the author. This is not meant to be an advisory to purchase or invest in products, services or solutions of a particular type or, those promoted and sold by a particular company, their legal subsidiary in India or their channel partners. No warranty or any other liability is either expressed or implied.
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