Designation of the DPO, Lecture 2

DPO of the processor

Article 37 applies to both controllers and processors with respect to the designation of a DPO. Depending on who fulfils the criteria on mandatory designation, in some cases only the controller or only the processor, in other cases both the controller and its processor are required to appoint a DPO (who should then cooperate with each other). It is important to highlight that even if the controller fulfils the criteria for mandatory designation its processor is not necessarily required to appoint a DPO.