Should we hire a "Data Protection Officer?"
A Data Protection Officer (DPO) is an employee or external consultant. Often a lawyer. With their expert knowledge of data protection law, the DPO oversees the company's handling and compliance with the rules.
You need to hire a DPO if your company's main activity is to process "particularly sensitive" personal data, regardless of company size. "Particularly sensitive personal data" can be, for example, sexual orientation, ethnic origin or genetic data.
A DPO is the contact person between the company and the Danish Data Protection Agency. This direct contact with the authorities means that the DPO must report directly to the company's top management.
The DPO has special protection against dismissal. You should be careful about what job the DPO is doing on the side and what conflicts of interest this may entail.
Similarly, you cannot use the company's lawyer as DPO, as this may conflict with both financial interests and confidentiality requirements.
