Handbook Certified Data Protection Officer: Practical Work Plan Guidance (Privacy and Data Protection 1)

This handbook provides practical guidance for the (junior, medior and senior) Data Protection Officer (DPO) to assemble a work plan as per applicable EU GDPR guidelines. At present EU’s GDPR is largely recognized as a gold standard all over the world, also for the ever-growing community of DPOs as per national legislations.

This publication is part of official mandatory training materials for Certified Data Protection Officer from the European Association of Data Protection Professionals (EADPP) as per the EADPP CDPO Certification Scheme and applicable CDPO Body of Knowledge (Part D) as provided by Privacad.

The practical approach followed in this richly illustrated handbook is of relevance for any (future) Data Protection Officer active in any part of the World performing tasks as per local, regional or international norms and regulations. This books explicitly explains the roles and responsibilities of the DPO as envisaged in the GDPR.

As stated by the European Data Protection Board (EDPB) it is best practice for the DPO to have a work plan. What does such a work plan look like? Providing an answer to that question lies at the core of this publication. Two key pillars are followed to assemble a professional and practical DPO work plan.

1. First, the text as enshrined in the General Data Protection Regulation (GDPR) itself codifies an important line of orientation in the embodiment of Articles 37 to 39 of the GDPR in which the designation, positions and tasks of the DPO are discussed.
2. Second, the typical role the DPO is playing in the “daily data protection practice” which can be inferred from, among others, an action plan (or work plan) from an enterprise (institution or organisation). In pursuit of compliance with the obligations pursuant to the GDPR, at least the following steps usually be distinguished.

1. Establish GDPR (privacy and data protection) policies.
2. Make an inventory of personal data.
3. Perform a GDPR (privacy and data protection) baseline.
4. Perform a GDPR (privacy and data protection) gap-analysis.
5. Perform a GDPR (privacy and data protection) implementation.
6. Perform GDPR (privacy and data protection) review and update.
7. Perform GDPR (privacy and data protection) assurance and audit.
8. Compose and communicate the GDPR accountability and reports.

According to the European Data Protection Board (formerly operating as WP29), the DPO (or the organisation) should avail of a work plan which the organisation will use as a basis for providing, among others, ‘necessary resources’ for the DPO. With the entry into force of the GDPR as of 25 May 2018, the need to work on professional maturity of the Data Protection Officer (DPO) became more and more urgent.

This handbook is part of the ‘Privacy and Data Protection’ series offered under auspices of Honorary Visiting Professor Romeo Kadir, acting Editor-in-Chief and author of the first publications in this series. At present professor Romeo Kadir (with over 25 years of experience as privacy and data protection professional) is Constituent President of the GDPR Certification Committee Academic Board of the European Association of Data Protection Professionals (EADPP) and President of the European Institute for Privacy, Audit, Compliance and Certification (EIPACC) and lecturer with the International Privacy Academy (Privacad). He holds several positions as Board Member, Corporate Consultant and Government Advisor related to privacy and data protection affairs.