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Submitted by admin on 12 August 2023

No. While it is beneficial and therefore encouraged, the DPA only requires data controllers to appoint a DPO if they:

  • are a public authority;
  • if they process personal data on a large scale;
  • if they process certain types of personal data;
  • if they fall within a prescribed class of controllers;

There is no express prohibition against an employee being appointed as the DPO; however, data controllers must be mindful that their duties as DPO do not conflict with their duties as an employee.