Communication is an essential skill for all professionals and more so if one is in a senior position and has to discharge conflicting responsibilities.
The Data Protection Officer is one such professional who requires a high level of communication skill since he/she has to discharge multiple types of responsibilities such as
- Dealing with employees below his/her cadre and advising on the legal aspects of data protection, querying on the operational aspects that may interfere with the legal requirements, making investigations etc,
- Dealing with employees who are peers or even superiors and discussing business strategies that may interfere with the legal requirements or suggesting implementation of policies and procedures that may cause disruption in other official relations.
- Dealing with the public (data subjects/Principals) who have complaints to be resolved.
- Dealing with the regulatory agencies who may have the authority to impose penalties on the organization and seek cooperation and assistance of the DPO in conducting inspections where the depositions often lead to penalties against the company.
If the DPO does not handle communication effectively with the data principals it could result in a data principal getting angry and escalating the compliant to the regulatory authorities. If the DPO does not handle the communication effectively with the regulatory agencies, it may result in penalties on the organization and the company may find fault with the DPO for his inefficient handling. If the DPO does not handle communication properly with subordinate employees, they may turn rogue and send out anonymous complaints to the regulatory authorities. If he does not handle the communication with the peers and superiors properly his job may be at stake.
Thus the DPO faces multiple challenges in communication where the strategy to be used may have to be different based on the context and the target of the communication. What is good for peers is not necessarily good for subordinates or outsiders or regulators.
At one place it may need “Tact” which can be construed as “Fraud” in another instance. At one place what is considered as “Confidence” may be treated elsewhere as “Arrogance”.
Thus “Effective communication” requires first the assessment of the situation, assessment of the parties involved, consequences of mis-communication and strategies to correct and track back when required.
Flexibility Vs Firmness
“Flexibility” in putting across one’s views is therefore one of the requirements of effective communication. However, “Flexibility” has to be balanced with “Firmness” where ever it is required and balancing the two would be one of the challenges. “An effective leader” knows when to be firm and when to be lenient and compassionate.
One of the requirements of leadership is to ensure that there is a spirit of “Cooperation” with the colleagues which can come from development of a “Superordinate goal” where each person accepts the common goal and understands his own role there in. In driving a train, the engine driver as well as the guard in the rear cabin both have a role to play and neither is superior or inferior if the superordinate goal is to successfully run the train to its destination. An Aircraft would never fly safely unless the maintenance staff and the ground staff work with the Pilot.
Verbal Vs Written
When communicating “Verbally” as against “Written” there is an element of “Voice Modulation” or “Body language” which by itself is an art and every body is not an expert of the same. Hence the base level communication that can be controlled is the written communication where the sender can take care through repeated checks and probably consultation with some body else whether the communication is achieving what it is expected to achieve.
In Oral or direct communication, the communicator is on his own and has to instantly react to the feedback from the target. If the target is an experienced communicator himself, he can easily manipulate the other through his skills which may be dysfunctional to the requirement of the situation.
Further Oral and written communication can be used in combination to achieve the desired result.
The choice of the mode of communication is therefore one of the decisions that needs to be taken by the DPO in vital communications.
Effective Listening
In most of the data principal’s communication, oral communication through a call back and listening to the complaint with empathy can be an effective way of defusing the anger of the complainant.
But the same strategy will not work with peers or superiors because they may not listen to you nor be patient enough to explain what is their concern. Persistent queries may be construed by them as the DPO over stepping his limits and there may be a natural tendency to shut out exposure of any of their own inadequacies. Keeping silent may also be construed as not being able to take a decision. Hence in many situations, it is damned if you speak and damned if you donot speak.
If verbal communication is not the strength of the communicator, he should play as per his strength and chose written communication. Well-articulated and well considered written communication is often better suited for handling peers, superiors and even the regulators.
Verbal communication in front of others has its own complications since a person may not mind an opposite view when expressed in private but when expressed in the presence of others, it could be rejected and misunderstood. In such cases also, a personal written note would be a better way to communicate since the recipient can ponder over the suggestions without the uncomfortable feeling that others are watching who gave the suggestion and whether it was a criticism of my own view point or not.
Motivation is the Key
The principles of motivation … what motivates the other person… is it the basic requirements of security, or the requirements of self actualization could be used to design the communication. Getting things done by subordinates can be made through a veiled threat or an incentive. But one cannot motivate the regulator to toe your line by any thing other than nurturing a feeling of empathy and compassion by the regulator with the company or its executives.
Attitude
Similarly the principles of understanding the “Attitude” of persons, the analysis of behavioural aspects such as what triggers an adult to adult behaviour vs parent to child or child to parent behaviour is extremely important. The choice of the lingo, some key words may trigger different types of behaviour in different persons and the ability to wade through this maze is an essential skill of a good communicator.
Thus “Effective Communication” skills for DPO require discussion of multiple aspects and development of relevant skills. It is not always possible for a person to be perfect in communication since the recipient of a communication is always at liberty to mis understand you. Hence “Perfect Communication” can be a goal but not always achievable. If we fail occasionally, it is time to learn and move on rather than brooding over the past mistakes.
No Communication
Finally some times, “Not Communicating” is also “Communication” and as long is it is not amounting to “Procrastination” or “Avoidance of decision”, delaying on the spot responses when it is not critical is also an effective way of handling a crisis. But deciding when to speak and when to remain silent or when to write down instead of picking up the phone or walking into the cabin for a discussion is an art of communication.
I welcome a debate on these aspects.
Naavi
