Re:No one’s ready for GDPR
by jdietrich on Wednesday May 23, 2018 @02:32PM
(#17136718)
A DPO is only mandatory if the core activities of your business include regular and systematic monitoring of individuals on a large scale, or include the processing on a large scale of specially protected information.
A shop only processes personal data as a secondary activity, with their core activity being selling merchandise. The data they do process is not in a specially protected category under the GDPR and pertains only to their business rather than the wider lives of their customers. They do not need a designated DPO.
A social media network, an ad tech company or a credit reference agency does need a DPO. A manufacturer of IoT gadgets that constantly phone home with a stream of usage data almost certainly needs a DPO. If the IoT gadget I sold you tells me what time you get home from work and what time you go to bed, that sounds an awful lot like "regular and systematic monitoring". A manufacturer of IoT gadgets that only phone home occasionally with fully anonymised error logs probably doesn't need a DPO.
A shop only processes personal data as a secondary activity, with their core activity being selling merchandise. The data they do process is not in a specially protected category under the GDPR and pertains only to their business rather than the wider lives of their customers. They do not need a designated DPO.
A social media network, an ad tech company or a credit reference agency does need a DPO. A manufacturer of IoT gadgets that constantly phone home with a stream of usage data almost certainly needs a DPO. If the IoT gadget I sold you tells me what time you get home from work and what time you go to bed, that sounds an awful lot like "regular and systematic monitoring". A manufacturer of IoT gadgets that only phone home occasionally with fully anonymised error logs probably doesn't need a DPO.