Data Protection Officer

Position Summary

The Data Protection Officer (DPO) is responsible for informing and advising the organisation on applicable data protection obligations, monitoring compliance with privacy laws and internal policies, advising on data protection impact assessments, and serving as a key contact point for data principals and regulatory or supervisory authorities.

The role supports a strong privacy governance framework across the enterprise covering applicable requirements under the EU/UK GDPR, India's Digital Personal Data Protection Act, 2023 (DPDP Act), and other relevant privacy and sectoral obligations. The DPO acts as an independent privacy adviser and monitor; accountability for compliance remains with the organisation and its management.

Reporting and Independence

• Functionally reports to the Board of Directors / concerned C level Executive

• Will have to coordinate with the Legal & Compliance function for day-to-day support, budgeting, and workflow alignment.

• Must be able to perform DPO duties independently and without instructions regarding the outcome of privacy advice, investigations, or regulatory interactions.

• Must have access to relevant records, systems, stakeholders, and resources necessary to perform DPO duties effectively.

• Must not hold responsibilities that determine the purposes and means of processing personal data or otherwise create a conflict of interest.

What the Role Needs to Achieve

• Provide independent advice on compliance with applicable data protection and privacy obligations.

• Monitor the organisation's privacy governance framework, controls, and accountability mechanisms.

• Promote privacy by design and privacy by default across products, services, internal processes, and vendor engagements.

• Support timely and compliant handling of data principal / data subject rights requests, grievances, and regulatory matters.

• Advise on privacy risk assessment, breach response, third-party processing risk, cross-border transfer compliance, and records of processing.

• Build privacy awareness across the enterprise and provide periodic reporting to senior leadership / Board.

Roles and Responsibilities

Governance, advice, and monitoring

• Advise the organisation on obligations under the DPDP Act, and other applicable privacy or sectoral laws, standards, and contractual commitments. Also need to align and implement best practices from Global standards such as GDPR

• Monitor compliance with privacy laws, internal policies, privacy controls, awareness programmes, and assigned accountability measures.

• Review and recommend updates to privacy policies, notices, standards, procedures, and control frameworks.

• Maintain visibility into major processing activities and support ongoing privacy governance, including Records of Processing Activities (RoPA) or equivalent processing inventories, where applicable.

• Advise on and monitor Significant Data Fiduciary (SDF) obligations under relevant section of DPDP Act, where the organization is notified as an SDF, including appointment of an independent data auditor, periodic Data Protection Impact Assessments, and enhanced accountability measures.

Privacy risk assessment and project review

• Advise on Data Protection Impact Assessments (DPIAs), privacy threshold assessments, and similar privacy reviews for new or changed processing activities.

• Review high-risk initiatives, systems, products, and data uses from a privacy compliance perspective before rollout.

• Advise business, technology, HR, procurement, and security teams on privacy by design, privacy by default, lawful basis, minimisation, retention, and transparency requirements.

• Review processing of personal data (persons below eighteen years of age) and personal data of persons with disabilities, ensuring verifiable parental / lawful guardian consent mechanisms and restrictions on tracking, behavioural monitoring, and targeted advertising, consistent with relevant Section of the DPDP Act.

Data principal / data subject rights and grievance handling

• Oversee and monitor the framework for responding to access, correction, erasure, objection, restriction, portability, and similar rights requests as applicable under relevant law.

• Act as or support the designated privacy contact point for grievance handling, escalation, and privacy-related enquiries, as applicable.

• Track response timeliness, quality, and closure of privacy complaints and regulatory correspondence.

• Ensure the DPO's business contact details are prominently and conspicuously published on the organisation's website, mobile applications, and privacy notices to enable data principals to raise queries, exercise their rights, or file grievances, in line with the DPDP Act

Incident and regulatory engagement

• Advise on the privacy aspects of personal data breaches and support the organisation's incident response, assessment, notification, remediation, and documentation process.

• Coordinate with Legal, Information Security, IT, HR, Communications, and business teams during privacy incidents and investigations.

• Serve as the point of contact or key liaison with supervisory authorities / regulators on privacy matters, where required.

• Advise on and monitor personal data breach notifications to the Data Protection Board of India and to affected data principals within the timelines and in the manner prescribed under the DPDP Act and the Draft DPDP Rules, and coordinate with Information Security on aligned CERT-In reporting where applicable.

Third-party and cross-border data processing oversight

• Review vendor and partner processing arrangements, including data processing agreements, due diligence materials, and privacy risk assessments.

• Advise on cross-border transfer mechanisms and safeguards, including contractual, technical, and organisational measures, where applicable.

• Work with procurement, legal, and business owners to improve third-party privacy governance and accountability.

• Monitor cross-border personal data transfer restrictions notified by the Central Government under relevant Section of the DPDP Act and maintain an up-to-date view of restricted jurisdictions and associated control adjustments; support Consent Manager engagement and oversight where applicable.

Awareness, audit, and reporting

• Design or sponsor privacy awareness and role-based training programmes across the organisation.

• Support internal and external privacy audits, certifications, and customer / regulator due diligence exercises.

• Prepare periodic privacy risk dashboards, compliance updates, and management or Board-level reports.

• Track legal and regulatory developments and recommend changes to controls, policies, and operating practices.

• Support the annual / periodic Data Protection Impact Assessments and independent Data Audits required of Significant Data Fiduciaries, including tracking of findings to closure and reporting of outcomes to senior leadership and the Board.

Essential Knowledge and Skills Required

• Strong working knowledge of GDPR, UK GDPR, India's DPDP Act, and practical privacy compliance frameworks.

• Clear understanding of DPO duties, independence requirements, conflict-of-interest safeguards, and accountability principles.

• Knowledge of data subject / data principal rights handling, grievance redressal, and privacy notice requirements.

• Hands-on familiarity with DPIA methodology, data mapping, records of processing, data retention, minimisation, and lawful basis analysis.

• Understanding of third-party risk, processor oversight, vendor assessments, and cross-border data transfer controls.

• Awareness of privacy-related technical and organisational controls, including encryption, access control, DLP, logging, and incident response.

• Working knowledge of ISO/IEC 27701 and related information security / privacy governance standards is preferred.

• Strong legal interpretation, policy drafting, communication, training, stakeholder management, and reporting skills.

Educational Qualifications

• Bachelor's degree in Law, Information Technology, Computer Science, Business Administration, Risk, Compliance, or a related field.

• Master's degree or specialised qualification in privacy, cyber law, governance, risk, or compliance is preferred.

• Relevant certification preferred: CIPP/E, CIPM, CIPT, FIP, ISO 27701 Lead Implementer / Auditor, CDPO, or equivalent privacy certification.

Experience

• 5+ years of experience in privacy, data protection, compliance, legal, risk, or a related governance role.

• Demonstrated experience supporting or monitoring GDPR and / or DPDP compliance programmes, rights handling, DPIAs, breach response, privacy notices, or policy development.

• Experience working with cross-functional stakeholders including Legal, IT, Security, HR, Procurement, and business units.

• Experience in vendor reviews, privacy controls, audits, or regulatory / customer due diligence is preferred.

• Experience presenting compliance matters, risk themes, or remediation status to senior management is desirable.