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Independence that is structural rather than asserted.

01Who it is for

Organisations required to designate a DPO, or choosing to; international groups needing a Portuguese-qualified DPO alongside a group function; organisations where an internal appointment creates a conflict of interest.

02The problem

“We need a DPO with real regulatory standing, genuine independence, and the seniority to be heard by the board.”

03Scope

The Article 39 tasks: monitoring compliance, advising, involvement in impact assessments, co-operation with and acting as contact point for the supervisory authority, plus board and management reporting.

04Method

  1. Appointment and notificationIncluding the notification to the CNPD and the internal communication that makes the role real.
  2. Initial assessmentWhat the organisation actually does, and where the exposure sits.
  3. Agreed reporting rhythmTo management and to the board, with the independence of the role preserved in writing.
  4. Standing availabilityFor the questions that arise between reports, which is where most of the value is.
  5. Annual plan and reportThe evidence that the function operated.

05Deliverables

  • The appointment itself
  • Monitoring reports
  • Board reporting
  • Regulatory interface
  • Training
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