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What is a data protection officer? Through the lens of a Master DPO

What is a data protection officer?
What is a data protection officer? Do companies really need to appoint one?

What is a Data Protection Officer?

A Data Protection Officer (DPO) is an officer that oversees data protection responsibilities, and the one who ensures that organizations comply with the Personal Data Protection Act (PDPA).  Under the PDPA, it is required for organizations to designate at least an individual as a DPO where their responsibilities include, but are not limited to:

  • Ensuring compliance with PDPA when developing and implementing policies and processes for handling personal data;
  • Fostering a data protection culture among employees and communicating personal data protection policies to stakeholders;
  • Managing personal data protection-related queries and complaints;
  • Alerting management to any risks that might arise with regard to personal data; and
  • Liaising with the PDPC on data protection matters, if necessary.

Types of complaints your DPO would deal with

As companies grow and expand their services to a mass number of people, their data collection and management also grows to the point that when mismanaged, they will face consequences set in the PDPA. There are a lot of documented reports and complaints on how companies manage collection and management of data, and here are just some of the complaints an organization’s DPO face according to Osome Blog Singapore

1. A competitor reporting on your subpar data protection practices or even a failure to appoint a DPO.

2. Complaints by individuals who are not satisfied with how your business is processing their personal data

3. Accidental disclosure of personal data

4. Unauthorized disclosure of personal data due to data breaches

Also Read: Data Protection Act of Singapore: Validity in the Post-pandemic World

We recently sat down with Sanjeev Gathani, Privacy Ninja’s Master DPO, to better understand the nuances of managing data protection compliance across various industries. We also explored how data protection officers like him handle digital acceleration and the ever-evolving business landscape.

Privacy Ninja’s very own Master DPO: Sanjeev Gathani

What is a data protection officer
Sanjeev Gathani | Privacy Ninja

Sanjeev Gathani is an experienced Governance, Risk and Compliance professional with more than 15 years of experience. He is one of Privacy Ninja’s highly passionate officers. He moved into the space of cybersecurity and privacy for more than 10 years now.

Sanjeev got into the DPO space when one of his friends asked him to enroll for a CIPM course, and he did. According to Sanjeev, as a master DPO of Privacy Ninja, it is an interesting role as things are fast and fluid, and there are loads of empowerment and opportunities to learn, grow, and contribute to Privacy Ninja. For him, the most challenging part is to be kept updated to the ever challenging world of security and privacy as there are loads of provisions to read and apply in the actual workplace. 

On a normal day, Sanjeev would clear emails, read on the latest updates on cybersecurity, and resolve issues of clients with practical solutions. For him, the misconception on DPOs is that one needs to have a string of certification to do the DPO role, but that’s not the case. One needs to fully understand the business, have loads of common sense, and one must be proactive and reactive to the times. It’s not a trivial role for sure, a role that is just as important as the CFO in a company.

According to Sanjeev, the biggest mistake businesses make when it comes to data protection practices is that these businesses do not do privacy by design and take privacy as a chore and hindrance to the business. This is not the case, and compliance to privacy regulations should be part of the business process and is embedded therein. It should be part and parcel of the business process and not otherwise.

“Use a common sense approach and perform privacy by design. Compliance to privacy regulations should not be considered as a chore,  but should be seen as part of the business process.”

An advice from Sanjeev to businesses with regards to the best data protection practices

Do Singapore companies really need to appoint a data protection officer?

Yes, or else the company will be fined. Back in 2017, Championtutor, a tuition agency, was fined $5,000 SGD due to failure to appoint a DPO. In 2019, the same happened to Horizon Fast Ferry but this time, the company was fined with a whopping $54,000 SGD simply because a DPO was not appointed and put in place arrangements to protect their employees’ and customers’ data. In these cases, there were no reported breaches that had occurred, there was only failure to appoint a DPO. That is how serious the Singapore authorities are when it comes to date protection.

Also Read: Going Beyond DPO Meaning: Ever Heard of Outsourced DPO?



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We have assisted numerous companies to prepare proper and accurate reports to PDPC to minimise financial penalties.


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