In September 2022, the European Data Protection Board (EDPB) announced its second annual coordinated action under the Coordinated Enforcement Framework (CEF) would focus on Data Protection Officer (DPO) appointments. Its first coordinated action over the use of Cloud-based services by EU public sector organisations concluded in January.
DPOs are a strategically important partner for Data Protection Authorities (DPAs) and an integral part of EU General Data Protection Regulation (GDPR) compliance. The rationale behind the CEF action is, therefore, self-evident. From mid-March, DPAs will prioritise DPO joint actions with activities ranging from raising awareness and gathering information to enforcement sweeps and joint investigations. In this article, IAPP Managing Director, Europe, Isabelle Roccia, describes the process behind the CEF and the potential outcomes of coordinated enforcement actions targeting DPOs, highlighting that this is "a good time for organisations to revisit their DPO functions and conduct hygiene checks."
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