Data protection is the process of safeguarding important information from corruption, compromise or loss. It is a key responsibility for any organization that collects, processes, stores and transmits sensitive data. There are several key roles that are involved in implementing a comprehensive data protection program.
Data Protection Officer
The data protection officer (DPO) is responsible for overseeing an organization’s data protection strategy and compliance with regulations. The General Data Protection Regulation (GDPR) mandates that organizations processing significant amounts of sensitive data appoint a DPO. Key responsibilities of the DPO include:
- Advising the organization on data protection obligations and ensuring compliance
- Monitoring compliance with data protection policies and procedures
- Conducting audits to identify gaps and vulnerabilities
- Providing training and raising awareness about data protection
- Liaising with supervisory authorities as the contact point for data protection issues
The DPO must have expert knowledge of data protection law and practices. They operate independently and report directly to the highest management level. Appointing a skilled and empowered DPO is essential for robust data governance.
Chief Information Security Officer
The chief information security officer (CISO) is tasked with establishing and maintaining the organization’s information security program. While the DPO focuses on data protection compliance and governance, the CISO is responsible for tactical security operations. Key duties include:
- Developing information security policies, standards and procedures
- Protecting systems and data from unauthorized access, malware and other cyber threats
- Managing IT security staff to administer controls and monitor networks
- Investigating security incidents and vulnerabilities
- Advising senior management on emerging security risks and solutions
The CISO collaborates closely with the DPO but has a broader security mandate focused on technical safeguards and risk management.
Data Owners
Data owners are accountable for specific datasets within an organization’s control. Their responsibilities include:
- Knowing what data they are responsible for and documenting it
- Determining appropriate access controls and classification levels
- Ensuring proper data handling as per policy
- Authorizing data processing activities
- Taking remediation steps in case of data breaches
Data owners are often business managers or department heads rather than IT staff. However, they need to work with IT and security teams to implement protections around the data they own.
Database Administrators
Database administrators (DBAs) manage the technology systems that store and organize data. Their data protection duties include:
- Configuring access controls and user permissions
- Performing backups and restoring data if needed
- Masking or anonymizing sensitive data for other uses
- Encrypting databases and data flows
- Monitoring database activity to identify unauthorized access
DBAs play an instrumental role in safeguarding databases containing confidential and regulated information.
IT Security Staff
IT security staff are responsible for executing data protection controls across an organization’s technology environment. Typical responsibilities include:
- Implementing security tools like firewalls, antivirus and encryption
- Patching vulnerabilities in software and operating systems
- Monitoring networks to detect intrusions and anomalies
- Analyzing security events and incidents
- Providing technical expertise and advice on security solutions
IT security staff are the frontline defenders against cyberattacks targeting sensitive data. They follow policies set by senior managers like the CISO.
Legal Counsel
In-house legal counsel plays an important advisory role in data protection. Key responsibilities include:
- Interpreting privacy laws and regulations
- Drafting compliant data protection policies and notices
- Vetting data processing agreements with third parties
- Handling investigations and litigation related to data breaches
- Providing guidance on legal obligations around data retention and disclosure
Legal expertise helps translate regulatory requirements into actionable data protection measures.
Data Protection Team Members
Larger organizations may establish dedicated data protection teams under the DPO to execute day-to-day programs. Responsibilities may include:
- Developing and updating data inventories and classifications
- Carrying out data protection impact assessments
- Validating lawful bases for data processing
- Facilitating subject access requests
- Managing vendor security assessments
- Conducting employee training on data handling
Having skilled staff focused exclusively on data protection allows systematic implementation of data governance. The DPO provides oversight across the different focus areas.
Third-Party Providers
Organizations frequently engage third-party providers for data processing and other services involving sensitive data. This creates shared accountabilities between the organization and vendor. Key responsibilities include:
- Performing due diligence in selecting reliable vendors
- Contractually requiring data protection controls in provider agreements
- Clarifying liability for data breaches in contracts
- Only sharing required data and limiting retention periods
- Monitoring vendor compliance through audits and assessments
Careful oversight of third-party data sharing is necessary to avoid increased risk exposure.
Individual Employees
While specialized roles focus on data protection strategy, governance and tools, individual employees play a crucial part by following policies and procedures. Their responsibilities include:
- Completing data protection and security training
- Only accessing personal data with authorization
- Immediately reporting lost or exposed data
- Storing and transmitting data securely as per policy
- Avoiding sharing credentials or other risky behavior
- Deleting or anonymizing data when no longer needed
Careless or improper data handling by employees can undermine even the strongest protections.
Information Users
Information users encompass all personnel that access protected data, including permanent employees, contractors and temporary staff. They have the following responsibilities:
- Understanding what data they can and cannot access
- Keeping credentials and access tools secure
- Only using data for authorized purposes
- Abiding by acceptable use policies
- Refraining from sharing accessed data with unauthorized parties
- Reporting suspicious activities around data
Anyone given access privileges for protected information has a duty to handle it appropriately.
Oversight Bodies
External oversight bodies like regulators monitor organizational compliance and sanction improper data practices. Key responsibilities include:
- Auditing data controls and investigating complaints
- Assessing security and compliance through questionnaires
- Imposing fines, directives or bans for regulatory violations
- Prosecuting criminal noncompliance under applicable laws
- Providing guidance on compliance best practices
While organizations aim to avoid enforcement actions, regulators ultimately enforce legal standards.
Summary of Key Data Protection Roles
This table summarizes the main data protection roles and associated responsibilities:
Role | Key Responsibilities |
---|---|
Data Protection Officer | Oversee data protection strategy and compliance |
Chief Information Security Officer | Manage information security program and controls |
Data Owners | Accountability for specific datasets |
Database Administrators | Secure and monitor database systems |
IT Security Staff | Implement technical safeguards and countermeasures |
Legal Counsel | Provide legal guidance on data practices |
Data Protection Team | Execute day-to-day data governance activities |
Third-Party Providers | Meet contractual data protection obligations |
Individual Employees | Follow policies and procedures |
Information Users | Handle data appropriately as authorized |
Oversight Bodies | Monitor and enforce compliance |
Data Protection Responsibilities for Different Organizational Roles
While specialized data protection roles bear primary responsibility, other organizational functions also contribute.
Human Resources
HR plays a key role through activities like:
- Conducting background checks on employees accessing sensitive data
- Including data protection in codes of conduct
- Providing training on appropriate data handling
- Imposing disciplinary sanctions for policy violations
- Ensuring physical security controls in work areas
Finance and Procurement
Finance and procurement functions enable data protection by:
- Allocating sufficient budget for data governance activities
- Requiring data security assessments in vendor contracts
- Purchasing approved data protection solutions
- Maintaining cyber liability insurance coverage
Internal Audit
Auditors promote data protection by:
- Evaluating data governance policy and control effectiveness
- Independently investigating data incidents
- Recommending risk-based improvements
- Verifying third-party provider assessments
Business Continuity Planning
Business continuity helps uphold data protection by:
- Implementing resilience to ensure data access during outages
- Defining recovery procedures in response to cyberattacks
- Establishing backup and retention strategies for key data
- Planning communications for data-related crises
Physical Security
Physical security supports data protection through measures like:
- Perimeter controls such as fencing, barriers and guards
- Facility access controls including identity checks
- Securing sensitive business areas and server rooms
- Surveillance monitoring of facilities
- Environmental safeguards against threats like fire
Importance of Defined Data Protection Roles and Responsibilities
Clearly defining data protection roles and responsibilities achieves several benefits for organizations:
- Ensures accountability for safeguarding confidential or regulated data
- Allows specialized focus on key governance, compliance and security tasks
- Supports appropriate segregation of duties across functions
- Enables oversight through competence checks and performance reviews
- Provides all workforce members clarity on their duties
- Demonstrates commitment to data protection during audits or investigations
Documented data protection roles backed by policies and procedures are hallmarks of a mature data governance program.
Conclusion
Protecting sensitive data requires a collaborative effort across multiple functions. While specialized roles like the DPO and CISO drive the overall program, other stakeholders like legal, IT staff, business managers, HR, physical security, providers and individual employees all contribute. Defined responsibilities allow organizations to embed data protection into everyday operations. Documented data governance roles and duties are also necessary to demonstrate accountability if breaches or compliance failures occur.