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๐Ÿ“ข๐Ÿ‡ต๐Ÿ‡ฑ Public sector and DPO

DPO | 30/03/2025

๐Ÿ“ข No DPO? No excuse
Source: DKN.5131.7.2024
Poland, UODO

๐Ÿ” On February 6, 2025, the Polish data protection authority, UODO, fined a public company, the Building Control Inspectorate of the Czฤ™stochowa district (PINB) €5,814 for failing to appoint a DPO, failing to notify the authority, and failing to publish its contact details.

๐Ÿ’ฅ Yet, since May 2018, the GDPR is clear:
๐Ÿ”น Any authority or public body must formally designate a DPO.
๐Ÿ”น This designation must be documented, official, clear
๐Ÿ”น Its contact details must be published and notified to the supervisory authority

โŒ What was complained of:

๐Ÿ”ธ A verbal appointment of a DPO, with no official designation.
๐Ÿ”ธ No clear legal designation document
๐Ÿ”ธ No official information published
๐Ÿ”ธ No notification to the authority before 2024
๐Ÿ”ธ Used internal organizational arguments: sick leave, reassignment of tasks, relocation of DPO, which do not justify this failure.

๐Ÿ“Œ Why is it serious?

๐Ÿ‘‰ The DPO plays a key role in the governance of personal data:
โœ” Compliance guarantor
โœ” Point of contact for data subjects
โœ” Interlocutor for the authority
โœ” Internal strategic advisor
Without a visible, identifiable DPO, there's no trust, no transparency, no response to people's rights.

๐Ÿ“ฃ To remember :

โœ… Appoint a DPO officially
โœ… Notify your data protection authority of his or her appointment
โœ… Publish his/her contact details on your website or internal channels
โœ… Document everything: role, missions, appointment, independence, resources

๐ŸŽฏ And above all: don't let an absence or departure create a vacuum!

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