As India moves ahead into the era of DPDPA, there is a rush for professionals to occupy the role of “DPO” in an organization. It is some times easy to grab a title but difficult to retain it and feel deserving to hold it. Hence those who aspire to be DPOs need to have and develop the credentials necessary to be a DPO.
When FDPPI was formed in 2018, one of the first objectives set for itself was to build an “Empowered” community of “Knowledgeable”, “Efficient” and “Ethical” Data Protection Professionals who contribute to the development of a “Secure Information Society” by lawful means.
The “Empowerment” comes from the “Ethical Attitude” which is as often absent in our approach to modern life. The knowledge we have, the skills we possess are meaningful only when they are applied with a noble objective. It is not enough if as a DPO we guide our organizations to be law abiding and meticuously follow the “Rules” when published. We need to be also “Ethical” in our approach and fulfil our duties as a ” Guardian of Privacy” of the “Data Principal”. A DPO is himself/herself is a “Fiduciary” and needs to be guided by the needs of the “Data Principal” when designing the compliance in an organization.
DGPSI as a framework of DPDPA Compliance recognizes this role of a DPO. As a guardian of Privacy of the Data Principal, the DPO is responsible to identify the Privacy Risks of the Data Principal and ensure that the risk is mitigated to the extent feasible, informed to the data principal and consent recorded.
In fulfilling this role, DPO will have a natural conflict with the business objectives of the organization which he has to navigate through. This requires leadership skills, persuasive communication skills and also empathy with the Data Principal. DPO also being a first respondent to the Data Principal needs the skill to negotiate and resolve disputes. Interpersonal skills to work harmoniously with the peers, superiors and regulators is also a desirable credential of the DPO.
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