Which companies must appoint a DPO?

If a company constantly employs at least ten persons who deal with the automated processing of personal data, the appointment of a DPO is mandatory according to German data protection law. This also includes external service providers such as an external accounting department.

If a company carries out out processing which is subject to a data protection impact assessment or processes personal data for business purposes for the transmission / anonymised transmission of personal data, or for the purposes of marketing or opinion research, then a DPO must be appointed, regardless of how many employees are involved in the processing of personal data.

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