Your DPO Is Your Regulator-Facing Shield. Do They Have a Policy Behind Them?
Under UK GDPR Articles 37–39, your Data Protection Officer isn't just a job title — they're a legally defined role with mandatory independence, specific statutory duties, prohibited conflicts of interest, and a direct line to the ICO. Appointing someone without a governance framework to back them up isn't compliance. It's a liability.
This ready-to-use DPO Responsibilities Policy gives FCA-regulated firms a complete framework governing every dimension of the DPO role — from mandatory appointment criteria and independence safeguards through to DPIA oversight, breach response authority, ICO cooperation, and Deputy DPO continuity arrangements.
Customise with your firm name. Put it in place before your next ICO interaction.
What's included: Mandatory vs voluntary DPO appointment assessment (Article 37 criteria) · Large-scale processing determination methodology · Independence requirements and prohibited roles matrix · Direct reporting line to Board/CEO structure · Resource allocation framework (financial, technical, administrative) · Conflict of interest assessment and annual declaration procedures · Confidentiality agreement requirements (Article 38(5)) · DPO competency standards (IAPP CIPP/E and equivalent) · 40-hour annual CPD commitment · Core statutory duties (Article 39) · DPIA consultation and oversight procedures · Subject access request coordination (one-month framework) · Data subject rights handling (Articles 15–22) · 72-hour ICO breach notification authority · Deputy DPO appointment, qualification, and activation procedures · ICO registration and regulatory cooperation obligations · Annual independence audit and performance assessment framework · Six-year documentation retention standard
Built for: Compliance officers, senior management, and HR teams at FCA-regulated firms appointing or formalising their Data Protection Officer arrangements.
Your DPO Is Your Regulator-Facing Shield. Do They Have a Policy Behind Them?
Under UK GDPR Articles 37–39, your Data Protection Officer isn't just a job title — they're a legally defined role with mandatory independence, specific statutory duties, prohibited conflicts of interest, and a direct line to the ICO. Appointing someone without a governance framework to back them up isn't compliance. It's a liability.
This ready-to-use DPO Responsibilities Policy gives FCA-regulated firms a complete framework governing every dimension of the DPO role — from mandatory appointment criteria and independence safeguards through to DPIA oversight, breach response authority, ICO cooperation, and Deputy DPO continuity arrangements.
Customise with your firm name. Put it in place before your next ICO interaction.
What's included: Mandatory vs voluntary DPO appointment assessment (Article 37 criteria) · Large-scale processing determination methodology · Independence requirements and prohibited roles matrix · Direct reporting line to Board/CEO structure · Resource allocation framework (financial, technical, administrative) · Conflict of interest assessment and annual declaration procedures · Confidentiality agreement requirements (Article 38(5)) · DPO competency standards (IAPP CIPP/E and equivalent) · 40-hour annual CPD commitment · Core statutory duties (Article 39) · DPIA consultation and oversight procedures · Subject access request coordination (one-month framework) · Data subject rights handling (Articles 15–22) · 72-hour ICO breach notification authority · Deputy DPO appointment, qualification, and activation procedures · ICO registration and regulatory cooperation obligations · Annual independence audit and performance assessment framework · Six-year documentation retention standard
Built for: Compliance officers, senior management, and HR teams at FCA-regulated firms appointing or formalising their Data Protection Officer arrangements.
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