Group Data Protection Officer: Appointment, Responsibilities, and Organizational Structure

Data protection in corporate groups: What matters for group-wide data protection

Ensuring compliance with data protection requirements in corporate groups is often more complex than in small businesses. Especially when groups consist of many subsidiaries, a high level of coordination is necessary to ensure that the processing of personal data throughout the group complies with GDPR requirements.

The topic of data protection in corporate groups is broad, ranging from the question of how data can be shared within the group to the harmonization of various international data protection policies.

To maintain an overview and avoid data protection breaches, a group data protection officer is required who, together with coordinators in various branches and countries, is able to manage data protection in a clear and organized manner.

What is a group data protection officer under the GDPR?

A group data protection officer, or group DPO for short, handles data protection and GDPR compliance in corporate groups and large enterprises. According to Art. 37 (2) GDPR, it is permissible for groups of companies to appoint a single, joint data protection officer.

Appointing a data protection officer for entire corporate groups has the advantage that one person maintains an overview of data protection across the group and serves as a central point of contact for employees, supervisory authorities, and data subjects.

What are the responsibilities of a data protection officer in a corporate group?

The group data protection officer takes a holistic, cross-functional approach to ensuring data protection compliance in large corporations, sister companies, holdings, corporate groups, as well as investment and private equity firms.

Does a group data protection officer have to manage data protection alone?

The group data protection officer is the primary point of contact for all data protection matters. This does not mean they have to handle all data protection tasks alone. Once a group reaches a certain size, the workload is shared among several people.

In this setup, the group data protection officer receives support in individual branches or countries from central coordinators who work with them to form a data protection team.

Local contacts are most familiar with the structures and specific data protection details of individual branches and can facilitate the work of the group DPO. This is important, among other reasons, because the GDPR requires them to be accessible from every single location.

What requirements apply to data protection officers for a corporate group?

To ensure they can properly manage data protection compliance within the group, group DPOs must possess versatile skills and experience in various areas:

What are the advantages of an external group data protection officer?

Data protection in a corporate group can be handled by internal or external data protection officers. Since organizing group-wide data protection is usually a full-time job, many large companies opt for external group data protection officers.

An external data protection officer for large companies  

• possesses comprehensive knowledge of the GDPR and all other relevant data protection regulations, such as the new Federal Data Protection Act (BDSG) or the Telemedia Act.

• understands how corporate groups function from a data protection perspective, where potential vulnerabilities lie, and how these must be addressed.

• maintains an objective view of the entire corporate group.

• acts as a professional point of contact for authorities, supervisory bodies, and data subjects.

• is able to quickly assess, grasp, and implement complex, cross-company processes based on extensive experience.

• has sound legal practice and is a TÜV or DEKRA certified data protection officer.

• continuously pursues further professional development at their own expense.

Group Data Protection by Professionals

DThe experts at Proliance have extensive experience across various industries and company sizes. Benefit from their data protection expertise.

Get external support now

How Proliance supports you with data protection in large enterprises

Corporate groups face unique challenges when it comes to data protection. In particular, cross-site coordination and documentation of data protection measures involve significant effort for large enterprises.

To make corporate compliance as efficient as possible, our group data protection officers therefore use the data protection software Proliance 360 as a digital collaboration tool. In a non-binding consultation, you can learn more about working with Proliance.