What are the functions and responsibilities of a data protection coordinator? How do they differ from data protection officers, and for which companies is this role particularly beneficial? A concise overview.
What is a data protection coordinator?
While the role of the data protection officer is clearly defined in the General Data Protection Regulation (Art. 38 GDPR), the term data protection coordinator is not explicitly mentioned. However, this position is highly valuable in practice, particularly in larger companies that must navigate complex data protection requirements.
The controller is obligated to provide the data protection officer with the necessary resources—both material and human—to effectively fulfil their duties. In this context, the role of a data protection coordinator serves as a vital support, helping to efficiently implement GDPR requirements across the organisation.
In large companies and corporate groups, appointing multiple data protection coordinators may be advisable to better manage tasks and streamline internal communication regarding data protection responsibilities.
Particularly when an external data protection officer is appointed, the data protection coordinator serves as a crucial interface between the external consultant and the company. Ideally, the internal data protection coordinator possesses sufficient expertise to accurately implement the external officer’s recommendations, while also having a deep understanding of the company’s internal processes and structures, allowing them to act as an effective bridge between both parties
Difference between data protection coordinator and data protection officer
The data protection officer, whether internal or external, holds a legally defined role with specific rights and obligations. Their primary responsibility is to ensure compliance with data protection regulations within the company, and they serve as the main point of contact for supervisory authorities and data subjects. In addition, they may not receive any instructions regarding their activities and (as an internal data protection officer) enjoy special protection against dismissal in order to guarantee their independence.
In contrast, the data protection coordinator is a company-appointed role with no specific legal obligations but plays a key supportive function. While the data protection officer focuses on advising and auditing, the data protection coordinator handles the operational implementation of data protection requirements and manages day-to-day tasks related to routine processes. They also act as a liaison, helping to apply the data protection officer´s recommendations across the organisation.
Responsibilities of a data protection coordinator
The data protection coordinator takes on a wide range of responsibilities, which can vary depending on the size and structure of the company. They act as a key link between the data protection officer and various departments, playing a critical role in internal communication on data protection matters.
The primary responsibility of the data protection coordinator is to support the data protection officer in implementing data protection requirements and ensuring compliance in day-to-day operations. This includes coordinating the handling of requests from data subjects or third parties, often pre-filtering these requests based on established procedures. As the internal point of contact for staff, the coordinator ensures that inquiries are addressed promptly, or escalated to the data protection officer, when necessary, if data subjects do not reach out directly.
Moreover, specific tasks that the company is responsible for can be delegated to the data protection coordinator. Examples include maintaining and updating data protection documentation, as well as assisting in the creation of records of processing activities. The coordinator ensures that all necessary information is gathered from relevant departments and properly coordinated with the data protection officer.
Key responsibilities of the data protection coordinator may include:
Contact for data protection issues
The data protection coordinator often serves as the first point of contact for employees with questions or concerns about data protection. They address these inquiries independently within their scope of responsibilities or, when needed, escalate them to the data protection officer for further guidance.
Documentation and reporting
The data protection coordinator may also be responsible for recording and documenting data protection incidents within the company. They play a key role in the escalation process and reporting system by gathering the necessary information and facts internally. This data is then passed to the data protection officer, who is responsible for conducting the risk assessment on a case-by-case basis.
Coordination of data protection projects
In large companies, data protection projects often span multiple departments. The data protection coordinator is responsible for coordinating these projects, ensuring that all stakeholders are informed and aligned to meet the project’s objectives in compliance with data protection requirements. This may include tasks such as the operational implementation of initiatives or developing a training concept for raising data protection awareness.
Advantages and disadvantages of the data protection coordinator
Appointing a data protection coordinator offers several benefits. They support the data protection officer by handling the operational aspects of data protection, easing their workload. Additionally, they enhance internal communication by acting as a liaison between departments. With their knowledge of the company’s internal structures, they can develop tailored solutions and ensure the efficient implementation of data protection regulations.
However, there are also challenges to establishing the role of a data protection coordinator. They require foundational training in data protection law and ongoing professional development to handle their delegated responsibilities effectively. A solid understanding of the company’s data protection obligations is essential. Moreover, the organisation must recognise the importance of this role within its internal data protection framework and be prepared to invest in the necessary resources and training.
Conclusion
Although the role of a data protection coordinator is not explicitly defined in the GDPR, it has proven to be highly valuable in practice. In larger organisations, the involvement of one or more data protection coordinators across group companies is crucial for efficiently, centrally, and verifiably implementing the extensive data protection requirements. When a corporate group establishes a data protection structure, this often includes designating coordinators within each entity. These coordinators act as the primary point of contact and the extended arm of the group data protection officer, helping to implement operational data protection responsibilities.
When an external data protection officer is appointed, it is beneficial to assign a central internal contact within the company. This improves communication and streamlines the overall implementation of data protection requirements. Synergies arise from the collaboration between the external officer’s technical expertise and the data protection coordinator’s deep knowledge of the company’s internal policies and structure, ensuring that requirements are met more effectively.
