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Data Protection Leader

Belgium: On the role of data protection officers: a Belgian inroad into the GDPR’s interpretation

Among the obligations bearing on data controllers and data processors, Article 37 of the General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) imposes the appointment of a data protection officer (‘DPO’) under specific circumstances. In all other cases, such designation is facultative, though encouraged by the Article 29 Working Party (‘WP29’) in its guidelines on DPOs. This role is at the heart of the accountability system preconised by the GDPR. Following the best practices formulated by the WP29, the Belgian Commission for the Protection of Privacy (‘CPP’) issued Recommendation No. 04/2017 of 24 May 2017 on the designation of a data protection officer in accordance with the GDPR in particular the admissibility of cumulating this role with other functions including that of security officer (CO-AR-2017-008) (‘the Recommendation’). In particular, the CPP tackles a question recurrently raised as to whether an individual can cumulate the role of DPO with another pre-existing role within an institution or a business and in particular, that of information security officer. Tanguy Van Overstraeten and Sophie Carton de Tournai, Global Head of Data Protection and Privacy and Associate respectively at Linklaters LLP, provide an overview of the Recommendation.

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