News
๐ข๐ต๐ฑ Public sector and DPO
๐ข No DPO? No excuse
Source: DKN.5131.7.2024
Poland, UODO
๐ On February 6, 2025, the Polish data protection authority, UODO, fined a public company, the Building Control Inspectorate of the Czฤstochowa district (PINB) €5,814 for failing to appoint a DPO, failing to notify the authority, and failing to publish its contact details.
๐ฅ Yet, since May 2018, the GDPR is clear:
๐น Any authority or public body must formally designate a DPO.
๐น This designation must be documented, official, clear
๐น Its contact details must be published and notified to the supervisory authority
โ What was complained of:
๐ธ A verbal appointment of a DPO, with no official designation.
๐ธ No clear legal designation document
๐ธ No official information published
๐ธ No notification to the authority before 2024
๐ธ Used internal organizational arguments: sick leave, reassignment of tasks, relocation of DPO, which do not justify this failure.
๐ Why is it serious?
๐ The DPO plays a key role in the governance of personal data:
โ Compliance guarantor
โ Point of contact for data subjects
โ Interlocutor for the authority
โ Internal strategic advisor
Without a visible, identifiable DPO, there's no trust, no transparency, no response to people's rights.
๐ฃ To remember :
โ
Appoint a DPO officially
โ
Notify your data protection authority of his or her appointment
โ
Publish his/her contact details on your website or internal channels
โ
Document everything: role, missions, appointment, independence, resources
๐ฏ And above all: don't let an absence or departure create a vacuum!