Chapter 4: Information Management and Privacy Risk Management
Privacy Team Roles - CPO, DPO, and Others
A privacy team may include a CPO, DPO, chief legal officer, privacy engineer, privacy manager, and privacy analyst, plus informal privacy champions and first responders. The DPO role (more common in Europe) must remain independent and free of conflicting duties.
| Role | Core focus |
|---|---|
| Chief privacy officer (CPO) | Develops and implements data-processing policies; typically a leadership position |
| Data protection officer (DPO) | Ensures legal compliance; more common in Europe; must be independent, no conflicting duties, not involved in processing decisions |
| Chief legal officer | Legal affairs of the whole organization; privacy is one of many areas |
| Privacy engineer | Ensures compliance through technical processes; relatively new title with significant responsibility |
| Privacy manager | Mid-level; develops, maintains, enforces privacy policies, often within a business unit |
| Privacy analyst | Often entry-level; manages legal/operational risk, assesses operations, builds policies and trainings |
Setting up the team involves establishing responsibilities and a reporting structure suited to the organization's size (which varies widely), designating a point of contact, defining how to evaluate the team's work, and operationalizing privacy - ensuring an ethical code of conduct with privacy as a core value.
Key terms - quick answers
What is “Chief privacy officer (CPO)”?
Leader charged with developing and implementing policies for data processing and proper handling of personal information.
What is “Data protection officer (DPO)”?
Role (more common in Europe) ensuring processing complies with legal privacy requirements; must be independent of data-processing decisions and free of conflicting duties.
What is “Privacy engineer”?
Ensures compliance through the organization's technical processes and that strategic direction supports affected customers.
What is “Privacy manager”?
Mid-level manager responsible for developing, maintaining, and enforcing privacy policies and procedures.