How do we apply the three DPO triggers?
The public-authority test uses section 7 of the Data Protection Act 2018. The other two triggers apply to : primary operations needed to achieve the organisation's objectives, not routine ancillary functions such as most employers' internal payroll or HR administration.
includes organised, recurring, or methodical tracking and profiling online or offline. To assess whether processing is , consider the number of people, volume and range of data, geographical extent, and duration or permanence. No single numerical threshold decides the issue.
- Apply the test to controllers and processors; both can have a mandatory appointment duty.
- Describe the core activity, monitoring, data, people, scale factors, geography, and duration.
- Distinguish an organisation's own ancillary HR processing from an HR service provider's core processing for clients.
- Revisit the decision after acquisitions, new services, changed monitoring, wider geography, or increased sensitive-data processing.
Binding appointment triggers, group and shared DPO options, accessibility, expertise, service-contract option, and contact publication.
Explains public authority, core activities, regular and systematic monitoring, large scale, voluntary appointments, and documented decisions.