Role: Data Protection Officer (DPO)

Document ID: SW-IMS-ROLE-006-v1.0
Effective Date: [TBD]
Review Date: [TBD]
Reports to: CEO
Current Assignment: [TBD - Name to be assigned by management]

Role Summary

The Data Protection Officer (DPO) is responsible for ensuring Swedwise AB's compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. The DPO acts independently to monitor data protection compliance, provide advice and guidance, and serve as the contact point for data subjects and supervisory authorities.

This role supports Swedwise's commitment to protecting personal data in all business activities, including consulting services at customer sites, SaaS service delivery, and internal HR and business operations.

Time Allocation

• Implementation Phase: 15-20% of working time
• Ongoing Operations: 10-15% of working time
• During Audits/Investigations: Up to 30% of working time
• DPIA Reviews: Variable (as needed)

This is a part-time functional role designed to be combined with other operational responsibilities appropriate to Swedwise's size (~35 employees). The role can potentially be combined with CISO, Risk Manager, or Legal/Compliance function, provided independence is maintained.

Key Responsibilities

1. GDPR Compliance Monitoring

• Monitor Swedwise's compliance with GDPR and other data protection regulations
• Oversee data processing activities across all business functions
• Review data processing agreements with customers and suppliers
• Monitor compliance with data protection policies and procedures
• Identify and address compliance gaps and risks
• Stay informed of GDPR developments and regulatory guidance
• Monitor compliance in consulting assignments at customer sites

2. Advice and Guidance

• Provide expert advice to management on data protection obligations
• Advise on Data Protection Impact Assessments (DPIAs)
• Guide business units on privacy-by-design and privacy-by-default
• Advise on data processing agreements and contracts
• Provide guidance on international data transfers
• Support decision-making on data protection matters
• Advise on new products, services, or processing activities

3. Data Protection Impact Assessments (DPIA)

• Determine when DPIAs are required for new processing activities
• Coordinate and oversee DPIA execution
• Review DPIA methodology and ensure adequacy
• Advise on risk mitigation measures identified in DPIAs
• Maintain register of completed DPIAs
• Review DPIAs for SaaS service developments
• Ensure DPIA findings are incorporated into project planning

4. Data Subject Rights Management

• Establish and maintain processes for handling data subject requests
• Oversee response to data subject access requests (DSARs)
• Monitor compliance with response timelines (1 month standard)
• Ensure appropriate verification of data subject identity
• Coordinate rectification, erasure, and restriction requests
• Handle data portability and objection requests
• Escalate complex or contentious requests to management
• Maintain register of data subject requests and responses

5. Training and Awareness

• Develop and deliver data protection training programs
• Ensure all staff understand their data protection obligations
• Provide role-specific training (e.g., for consultants, developers, HR)
• Create and maintain data protection awareness materials
• Conduct privacy awareness campaigns
• Monitor training completion and effectiveness
• Update training materials as regulations evolve

6. Breach Management

• Establish data breach response procedures
• Assess data breaches and determine notification requirements
• Coordinate breach investigations and containment
• Notify supervisory authority within 72 hours (when required)
• Notify affected data subjects (when required)
• Document all data breaches and responses
• Report breaches to management and affected customers
• Conduct post-breach reviews and lessons learned

7. Records of Processing Activities (ROPA)

• Maintain comprehensive Records of Processing Activities
• Document all processing activities across Swedwise
• Review and update ROPA at least annually
• Ensure ROPA includes all required information per GDPR Article 30
• Make ROPA available to supervisory authority upon request
• Coordinate ROPA updates with business units
• Maintain separate records for controller and processor activities

8. Third-Party and Supplier Management

• Review data processing agreements with processors
• Ensure adequate safeguards in supplier contracts
• Assess data protection compliance of key suppliers
• Monitor international data transfers and transfer mechanisms
• Review cloud service provider data protection measures
• Coordinate with Legal/Procurement on data protection clauses
• Maintain register of data processors and sub-processors

9. Supervisory Authority Liaison

• Act as primary contact point with data protection authority (IMY in Sweden)
• Respond to supervisory authority inquiries and requests
• Report data breaches to IMY when required
• Coordinate supervisory authority audits or investigations
• Participate in prior consultations when required
• Maintain cooperative relationship with IMY
• Stay informed of IMY guidance and decisions

10. Data Subject Contact Point

• Serve as accessible contact point for data subjects
• Publish DPO contact information in privacy notices
• Respond to data subject inquiries about their rights
• Handle complaints from data subjects
• Escalate serious complaints to management
• Maintain register of data subject contacts and complaints
• Ensure professional and timely responses

11. Privacy Governance

• Develop and maintain data protection policies and procedures
• Ensure privacy governance framework is appropriate
• Coordinate privacy governance with IMS and ISMS
• Review privacy notices and consent mechanisms
• Monitor legitimate interests assessments
• Oversee vendor due diligence from privacy perspective
• Ensure data retention schedules are implemented

12. Documentation and Reporting

• Maintain comprehensive data protection documentation
• Report data protection status to CEO and Management Team
• Prepare annual data protection report
• Document advice provided and decisions taken
• Maintain audit trail of data protection activities
• Provide data protection metrics for management review
• Report significant risks and issues to management

Authority

The DPO has authority to:

Independence and Decision-Making Authority

• Operate independently without instruction on data protection matters
• Report directly to highest management level (CEO)
• Access all personal data and processing operations
• Conduct data protection audits and investigations
• Require information and cooperation from all business units
• Recommend suspension of processing that poses high privacy risk
• Escalate data protection issues directly to CEO and Board

Limitations

• Cannot be dismissed or penalized for performing DPO duties
• Cannot be given tasks that create conflict of interest
• Does not personally decide on data processing purposes and means
• Advises but does not override business decisions (unless legal breach)
• Major policy changes require management approval

Required Competencies

Education and Qualifications

Minimum:

• University degree in Law, IT, Information Security, or related field
• OR equivalent practical experience in data protection (3+ years)
• Thorough understanding of GDPR and EU/Swedish data protection law

Preferred:

• Legal background with specialization in data protection
• Formal data protection or privacy certification
• ISO 27001 or information security knowledge

Professional Certifications (Recommended)

Highly Recommended:

• Certified Information Privacy Professional/Europe (CIPP/E)
• Certified Information Privacy Manager (CIPM)
• DPO certification from recognized provider

Valuable:

• Certified Information Privacy Technologist (CIPT)
• ISO 27001 Lead Implementer or Lead Auditor
• CISSP or CISM (for technical understanding)

Experience

Essential:

• Minimum 3 years experience in data protection or privacy
• Understanding of GDPR requirements and practical application
• Experience with data protection in business context
• Knowledge of Swedish/EU data protection law
• Familiarity with IT and information security

Desirable:

• Previous DPO or similar role experience
• Experience in IT consulting or SaaS environment
• Experience handling supervisory authority interactions
• Data breach response experience
• DPIA facilitation experience
• International data transfer experience

Skills and Competencies

Legal and Regulatory Knowledge:

• Expert knowledge of GDPR and EU data protection law
• Understanding of Swedish data protection legislation
• Knowledge of ePrivacy Directive and related regulations
• Familiarity with sector-specific regulations (if applicable)
• Understanding of international data transfer mechanisms
• Awareness of privacy trends and regulatory developments

Technical Knowledge:

• Understanding of data processing technologies
• Knowledge of information security principles
• Familiarity with cloud computing and SaaS models
• Understanding of encryption and pseudonymization
• Knowledge of data lifecycle management
• Awareness of privacy-enhancing technologies

Business and Management Skills:

• Strategic thinking and risk assessment
• Stakeholder management and influencing
• Project coordination and management
• Communication (written and verbal) in English and Swedish
• Training and presentation skills
• Problem-solving and analytical abilities
• Negotiation skills

Personal Attributes

• Strong ethical standards and integrity
• Independent and objective mindset
• Diplomatic and tactful in handling sensitive matters
• Attention to detail and thoroughness
• Ability to balance privacy with business needs
• Calm under pressure (especially during breaches)
• Proactive and self-motivated
• Continuous learner on privacy topics
• Confident in challenging decisions when necessary

Key Relationships

Stakeholder	Nature of Interaction	Frequency
CEO	Reports to; receives resources; escalates serious issues	Bi-weekly
Management Team	Privacy governance; strategic advice; risk reporting	Monthly
CISO	Coordinates on information security and privacy alignment	Weekly
IMS Owner	Coordinates on IMS integration; audit coordination	Bi-weekly
Legal/Compliance	Coordinates on legal matters and contract reviews	As needed
IT/Technical Lead	Technical controls; system access; data architecture	Monthly
HR Manager	Employee data processing; HR systems; staff privacy	Monthly
Customer Success	Customer data processing; customer inquiries	As needed
Sales Team	Contract reviews; customer privacy requirements	As needed
Development Teams	Privacy-by-design; SaaS data processing; DPIAs	As needed
Data Subjects	Responds to rights requests; handles inquiries	As needed
IMY (Swedish DPA)	Breach notifications; inquiries; consultations	As needed
External Auditors	Privacy audits; evidence provision	During audits

Relationship with Other IMS Roles

CISO (Chief Information Security Officer)

• Collaboration Model: Complementary roles with significant overlap in data security
• Division of Responsibility: DPO owns GDPR compliance and privacy; CISO owns information security and ISO 27001
• Interaction: Close collaboration on data security controls, breach response, access management, and technical safeguards
• Note: Can be combined with CISO role if independence maintained and no conflict of interest

IMS Owner

• Collaboration Model: DPO participates in IMS but operates independently
• Division of Responsibility: IMS Owner coordinates overall IMS; DPO ensures privacy compliance is integrated
• Interaction: Joint management review preparation; coordinated audit activities; shared documentation control

Risk Manager

• Collaboration Model: Complementary roles in risk management
• Division of Responsibility: Risk Manager owns enterprise risk; DPO owns privacy risk assessment and DPIAs
• Interaction: Privacy risks are integrated into enterprise risk register; joint risk review sessions
• Note: Can potentially be combined with Risk Manager role if appropriate expertise

Performance Indicators

KPI	Target	Measurement Method
GDPR Compliance Rate	100% of processing activities compliant	Compliance audit findings
Data Subject Request Response	100% within 1 month	DSAR tracking register
Breach Notification Timeliness	100% to IMY within 72 hours (when required)	Breach register
DPIA Completion	100% of high-risk processing has DPIA	DPIA register
ROPA Currency	100% of processing activities documented	ROPA review
Privacy Training Completion	100% of staff trained within 3 months of joining	Training records
Data Processing Agreements	100% of processors have valid DPA	Contract register
Policy Review Currency	100% of privacy policies reviewed annually	Document control register
Supervisory Authority Issues	Zero enforcement actions or penalties	IMY communications
Privacy Audit Findings	Zero critical findings in privacy audits	Audit reports

Independence and Conflict of Interest

Independence Requirements (GDPR Article 38)

The DPO must:

• Report directly to highest management level
• Not receive instructions regarding performance of DPO tasks
• Not be dismissed or penalized for performing DPO duties
• Be given necessary resources and access to personal data
• Have adequate time allocation to perform DPO duties
• Not be evaluated negatively for independence in DPO role

Conflict of Interest Avoidance

The DPO role cannot be combined with positions that:

• Determine purposes and means of personal data processing at strategic level
• Include roles such as: CEO, COO, CFO, CMO, Head of IT, Head of HR (as primary role)
• Create inherent conflict between business objectives and data protection

The DPO role can potentially be combined with:

• CISO (if focus is on implementing controls, not determining processing)
• Risk Manager (if appropriately scoped)
• Legal/Compliance Officer (if not determining business strategy)
• Quality Lead (if no processing decision authority)

For Swedwise: Given company size, combining DPO with CISO or Risk Manager is feasible provided:

• Clear separation of duties is documented
• DPO acts independently on privacy matters
• No decision-making authority on processing purposes and means
• Independence is maintained and demonstrable

Delegation and Backup

During Planned Absence

Responsibilities are delegated in the following manner:

• Data subject requests: Delegated to CISO or designated privacy coordinator
• Urgent breaches: Directed to CEO with CISO support
• Routine compliance monitoring: Can be deferred for short absences
• IMY contact: Backup contact designated (CISO or Legal)

Deputy Role

A deputy DPO should be designated from:

• CISO (most likely)
• Risk Manager
• Legal/Compliance Officer

The deputy should:

• Receive appropriate data protection training
• Be familiar with GDPR requirements and Swedwise's processing activities
• Understand breach notification procedures
• Have access to all relevant documentation

Success Factors

The DPO will be successful when:

1. Compliance: Swedwise demonstrates full GDPR compliance with no enforcement actions
2. Culture: Privacy awareness is embedded throughout the organization
3. Efficiency: Data subject requests are handled promptly and professionally
4. Integration: Privacy is considered early in all new initiatives (privacy-by-design)
5. Transparency: Data processing is transparent and well-documented
6. Trust: Customers and employees trust Swedwise's data protection practices
7. Proactivity: Privacy risks are identified and mitigated before issues arise
8. Reputation: Swedwise is recognized for privacy excellence in the market
9. Independence: DPO operates independently and provides objective advice
10. Preparedness: Breach response is well-prepared and tested

Document Control

Version	Date	Author	Changes
1.0	[TBD]	[Author]	Initial release

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Approval

Role	Name	Signature	Date
CEO
Management Team