DPO role

1) Appointment and legal mandate

Purpose: to ensure compliance with privacy requirements (GDPR/UK GDPR/ePrivacy and local regulations), act as an independent control point and contact person for regulators/data subjects.

• systematic and large-scale monitoring of subjects (profiling, antifraud, RG triggers);
• large-scale processing of special categories of data (for example, biometrics liveness in KYC);
• status of "public interest processing organization" (rare for iGaming, but found in related projects).

2) Principles of independence and accountability

Independence: DPO does not receive guidance on the content of conclusions; conflict of interest is not allowed (DPO must not be both Head of Security, CTO, CMO, Product Owner for affected processes).
Subordination: direct accountability to C-level/Board of Directors; access to all data/systems/contracts.
Resources: budget, access to lawyers, analysts, tools (RoPA, DSAR, DLP/logs).
Sanction protection: banning fines/dismissals for DPO duties.

3) Role, area of responsibility and boundaries

• Legal advice, Privacy by Design/Default;
• RoPA maintenance/supervision, participation in DPIA/DTIA;
• personnel training, development of privacy/cookie/DSAR policies;
• monitoring of storage and deletion periods, right exercise tests;
• interaction with supervisory authorities and data subjects;
• monitoring privacy incidents and checking notifications (including in 72-hour windows);
• independent opinions and recommendations (advice & challenge).

DPO is not responsible for operational risk ownership (this is the zone of process owners: Product, Security, Compliance, Data). DPO - "secondary circuit" of control.

4) RACI (enlarged)

5) DPO role metrics and KPIs

SLA DSAR: confirmation ≤ 7 days, execution ≤ 30 (share on time ≥ 95%).
DPIA coverage:% high-risk changes with DPIA ≥ 95%.
Retention compliance: the share of systems with uninstall/anonymization auto-tasks ≥ 90%.
Privacy incidents: MTTD/MTTR for privacy incidents, the share of notifications within 72 hours is 100%.
Training:% of employees trained in privacy ≥ 98% (annually).
Vendor privacy score: the share of vendors with up-to-date DPA/SCCs/DTIA is 100%.

6) Processes (SOPs) overseen by DPO

6. 1 DSAR (rights of subjects)

1. Acceptance of request (portal/mail) → 2) Identity verification → 3) Scope assessment → 4) Collection of data from systems/vendors → 5) Legal review of restrictions → 6) Response/refusal (with justification) → 7) Logging and improvements.
Controls: two-factor verification; red lines - do not disclose PII third parties, anti-fraud secrets.

6. 2 DPIA/DTIA

Change screening (feature flag in CAB) → risk classification → DPIA (risks/measures) → DPO/Legal approval → backlogging of measures (CAPA) → post-inclusion of verification.
DTIA when cross-border: mechanism (SCCs/IDTA), technical measures (E2EE/client keys), data geography.

6. 3 Incident/Leak Management

Assessment of "personal risk" to subjects; preparation of notifications to regulator/users; coordination of texts; timeline log; post-mortem on privacy.

6. 4 RoPA and Data Map

Live Stream Registry: Goals, Grounds, Recipients, Deadlines, TOMs, Automated Solutions/Profiling.
Quarterly review and link to architecture/ETL.

6. 5 Cookies/CIW & Marketing

Granular consents (TCF/equivalents), version logging; preference centers; separation transactional vs marketing communication; Affiliate/SDK control.

7) Interaction with regulators and subjects

Single point of contact: public DPO email and mailing address.
Comm-principles: facts, measures, terms; avoid hypotheses and marketing language.
Dossier of regulatory contacts: taking into account requests, answers, deadlines, appendices.

8) Conflicts of interest and permissible overlaps

Cannot be combined with CTO/Head of Security/Head of Marketing/Product Owner roles.
Combinations with a compliance adviser are allowed if independence and veto power are preserved and formalized.

9) Vendors and cross-border transfers (overseen by DPO)

Prior to conclusion: due diligence (ISO/SOC2, incidents, geography, sub-processors, TOMs), DPA, cross-border mechanism (SCCs/IDTA), DTIA.
In operation: register of sub-processors, change notifications, incident test, periodic questionnaires and selective audits of PII access logs.
Offboarding: revocation of accesses, deletion/return of data, closing act.

10) Privacy by Design/Default - embedding

Checklist in CAB: purpose/reason, minimization, pseudonymization, shelf life, cookies/SDK, DPIA screening, consent/objection mechanism, test environment without "live" PII.
Policy "data is closed by default"; the principle of least rights; system roles and secret management.

11) Patterns and artifacts

Public Privacy Policy (version, DPO contacts).
Cookie policy and CMP banners (categories, vendor register, consent log).
DSAR procedure (forms, SLA, verification, FAQ).
DPIA/DTIA template (risk matrix, measures, residual risk, go/no-go solution).
RoPA register (tabular template).
Privacy Incident Response Plan (72 hours, addressees, notification templates).
DPA/SCCs/IDTA (application templates, list of sub-processors).

12) Training and privacy culture

Onboarding for all + annual update; special courses for Support/Marketing/Engineering.
DSAR and tabletop leak training; assimilation control (quizzes, metrics).
Communications "privacy moments" in release sprints.

13) DPO Implementation Roadmap

Weeks 1-2: independence assignment/audit, data map and RoPA, vendor registry, policy inventory.
Weeks 3-4: CMP and Preference Center Launch, Policy Update, DSAR/DPIA/Incident Templates, Training.
Month 2: vendor audit (DPA/SCCs/DTIA), pilot DPIAs, retention jobs automation, DSAR test.
Month 3 +: quarterly reports to the Council, leak drills, threshold audits, improvement plan.

14) DPO reporting to Council (quarterly - minimum composition)

KPI/Incidents/DSAR; DPIA/DTIA status critical risks and recommendations; CAPA progress; vendors and cross-border; roadmap for increasing maturity.

15) DPO Maturity Checklist

• Independence is formalized (mandate, chain of command, no conflict).
• DPO contacts published; there is a register of regulatory interactions.
• RoPA is up to date, data flow map is supported.
• DPIA/DTIA are embedded in the CAB; a solution log is maintained.
• DSAR process with SLAs and logs; test queries were run.
• Privacy/cookie/retention policies are up-to-date and localized.
• The Sub-Processor Registry is public/accessible; DPA/SCCs/IDTA are relevant.
• Personnel training ≥ 98% coverage; tabletop exercises passed.
• Metrics/KPIs are tracked; the quarterly report to the Board is being implemented.

16) Example JD (Job Description) - squeeze

Responsibilities: oversight of privacy, DPIA/DTIA, DSAR, incidents, training, regulatory contacts, reporting, vendor audit.
Requirements: 5 + years experience in privacy/compliance, knowledge of GDPR/UK GDPR/ePrivacy, experience of interaction with supervision, tech. literacy (clouds, encryption, logging).
Soft-skills: independence with "veto power," communications, facilitation of conflicts of interest.

TL; DR

DPO is an independent "second circuit" of privacy: advises, controls, maintains RoPA/DPIA/DSAR, is responsible for notifications and interaction with regulators, trains and reports with the Council. Strong DPO = built-in privacy in the product, manageable risks and provable integrity in all jurisdictions.