What to consider when choosing and appointing your data protection officer

Dr. Bernd Schmidt

Data Protection Data Protection Officer

The data protection officer plays a key role in your data protection organization and usually works with you for a very long time. With a good decision, you can set the course for successful data protection management, but you can also go wrong. Learn more about what to look out for during the selection and appointment of a data protection officer.

Important criteria when selecting a data protection officer

Choosing the right data protection officer for your company can be crucial to the success of your data protection management. There are various criteria that you should know and consider.

Experience and expertise

A data protection officer should have in-depth experience and expertise in data protection law and technology. It is important that the person is familiar with the relevant data protection laws and regulations and is able to implement them effectively.

Industry-specific knowledge

Your data protection officer should know your business. Data protection requirements can vary greatly depending on the industry and customer.

Communication skills

A Data Protection Officer should have good communication skills to engage colleagues and raise awareness of data protection in your organisation. The person should be able to explain data protection topics in an understandable way and provide training so that employees can comply with and implement data protection requirements.

Independence and neutrality

It is important to ensure that the data protection officer acts independently and neutrally. The person should not come into conflict with other company interests and should be able to make unbiased decisions. People in management positions or with responsibility for data protection-critical areas are therefore not suitable candidates.

Continuous further training

Data protection is constantly evolving. This applies to technology as well as regulation. It is therefore important to ensure that your data protection officer is prepared to keep up to date with the latest developments in data protection. You must be prepared to support this with the appropriate resources.

Internal or external appointment?

It is possible to recruit a data protection officer from your own staff, find and hire a new candidate or outsource the appointment to a law firm or consultancy. All options have advantages and disadvantages.

Internal candidates know their company and generally have a better connection to the organisation. They are aware of what is happening and ideally know what needs to be done to improve data protection. However, they may face the challenge of the in-house advocate, who is not listened to, or not listened to in the same way as the external adviser. The external adviser usually has more experience and can use knowledge from other clients. The internal data protection officer usually only introduces a new HR system once. The external adviser has usually done this more often. However, they need a good connection to the company so that they can bring their expertise to bear.

Which option you decide on should ultimately depend on how you combine the greatest possible expertise with the connection to the organisation. You can make a good or a bad choice, but there are no one-size-fits-all solutions.

The appointment of a data protection officer

If you have made the right choice, the appointment is the minor obstacle. The data protection officer is then appointed by the appointment document, reported to the responsible data protection authority via their online form and announced to the team.


When selecting and appointing your data protection officer, you should proceed carefully to ensure that the person has the necessary qualifications and is suitable for the task. The right choice of data protection officer is a crucial building block for good data protection management.