Appointing a Data Protection Officer (DPO) is mandatory for organisations that:
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Are public authorities or bodies, except for courts acting in a judicial capacity.
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Conduct large-scale systematic monitoring (e.g., CCTV, online behaviour tracking).
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Process large volumes of sensitive personal data such as health, biometric, or racial data.
The DPO must act independently, without conflict of interest, and report directly to the highest level of management. This independence ensures that the DPO can advise and monitor compliance objectively.
Failure to appoint a DPO where required constitutes a breach of the UK GDPR and may result in enforcement action by the ICO.
