Hiring a DPO with a real security culture
How to hire a data protection officer who can work with security: GDPR rules, backgrounds that work, skills to test, conflicts of interest and a case study.
Many organisations appointed a data protection officer to tick the compliance box, then discovered during their first data breach that the DPO and the security team do not speak the same language. Yet the GDPR makes security of processing an obligation in its own right. This guide helps you define the role, choose the right background and check in interview that your future DPO will work hand in hand with the CISO.
What the GDPR expects from a DPO
The framework is set by Articles 37 to 39 of Regulation (EU) 2016/679, available on eur-lex.europa.eu. In France, the CNIL publishes practical guidance on cnil.fr explaining how it applies.
Appointing a DPO is mandatory in three cases: public authorities and bodies, organisations whose core activities involve regular and systematic monitoring of individuals on a large scale, and those processing special categories of data or criminal records data on a large scale. Outside these cases, many companies appoint one voluntarily.
The regulation also sets several rules that shape the hiring process:
- Expertise: the DPO is designated on the basis of professional qualities, in particular expert knowledge of data protection law and practice.
- Internal or external: the DPO can be an employee or work under a service contract. A group can appoint a single DPO for several entities.
- Independence: the DPO takes no instructions on how to carry out their tasks, cannot be penalised for performing them and reports to the highest level of management.
- Conflicts of interest: the DPO may hold other duties, provided they do not create a conflict of interest.
- Resources: the organisation must provide the necessary resources and involve the DPO in a timely manner in all data protection matters.
The DPO's legal tasks are to inform and advise, monitor compliance, advise on data protection impact assessments and cooperate with the supervisory authority, acting as its contact point.
Why security culture makes the difference
On paper, the DPO is a compliance role. In practice, a large share of the work touches security.
- Security of processing: Article 32 requires technical and organisational measures appropriate to the risk. The DPO must be able to judge whether the encryption, access management or backups described by IT are real and sufficient.
- Data breaches: Article 33 requires notifying the supervisory authority without undue delay and, where feasible, no later than 72 hours after becoming aware of a breach, unless it is unlikely to result in a risk to individuals. During those 72 hours, the DPO works alongside the incident response team and must understand what they are told about the compromised scope, the available logs and the exfiltrated data.
- Impact assessments (DPIA): they require assessing risks to individuals, and therefore understanding the technical threats a processing operation faces.
A DPO with no technical grounding depends entirely on what IT chooses to explain. A DPO who understands the basics can ask the right questions, spot a vague answer and move topics forward without needless friction.
DPO, CISO, GRC analyst: who does what
These three roles often overlap and are sometimes confused. Drawing the line before you publish the job ad avoids many misunderstandings.
| Role | What it protects | Main duties | Watch point |
|---|---|---|---|
| DPO | The rights and freedoms of the people whose data is processed | Records of processing, DPIAs, data subject rights, breaches, liaison with the authority | Independence and no conflict of interest, as required by the GDPR |
| CISO | The information system and the organisation's assets | Security policy, cyber risk management, steering measures and incidents | Decides on measures the DPO must be able to challenge |
| GRC analyst | Compliance with frameworks and the quality of evidence | Risk analysis, gap tracking, questionnaires, suppliers | Often a valuable support for both the DPO and the CISO |
Combining the DPO and CISO roles
In small organisations, it is tempting to give both hats to the same person. The risk is real: the DPO must be able to review security measures the CISO decided on. The European guidelines on DPOs list senior management positions, including the head of IT, among those that typically create a conflict of interest. Before combining roles, assess the situation case by case and document your reasoning. If you are not large enough for two positions, our article on part-time versus full-time CISOs offers other options.
Where good DPOs come from
There is no single path. Each talent pool brings its strengths and blind spots.
Data protection lawyers
They know the text, the case law and the regulator's positions. They write precisely and can decide on a lawful basis. Check: how comfortable are they with an architecture diagram or an incident report?
Security and IT backgrounds
Former administrators, IT project managers, security consultants. They understand technical measures and quickly spot what is missing. Check: their legal rigour and their ability to defend individuals' rights against business pressure.
GRC, audit and compliance backgrounds
They know how evidence works, understand frameworks and track action plans. Our guide to hiring a GRC analyst covers this pool. Check: their real knowledge of the GDPR beyond the headline principles.
In France, the CNIL has set up a DPO skills certification issued by approved bodies. It confirms a baseline of knowledge, which is useful, but it does not tell you how a candidate behaves when a breach lands on a Friday evening. Our article on what certifications really say applies here too.
Skills to test
Focus the assessment on what the job demands day to day:
- GDPR mastery: lawful bases, retention periods, data subject rights, transfers outside the EU.
- Technical literacy: do they understand what logging, encryption at rest or an access review actually involve?
- Breach handling: can they qualify a breach, assess the risk to individuals and prepare a notification?
- Running a DPIA: can they run the exercise with business and technical teams and turn it into concrete measures?
- Supplier assessment: do they read a data processing agreement and a security questionnaire with a critical eye?
- Teaching ability: can they explain a constraint to a marketing lead without putting them on the defensive?
- Independence: can they hold a position in front of management, with arguments?
A case study that reveals the level
General GDPR questions show what a candidate has read. A concrete case shows how they think. Here is a simple exercise to prepare.
Give the candidate a short scenario: the security team has just detected that a service account on a customer relationship management tool was used from an unusual address, and that an export of the customer database was launched. Logs only cover part of the period. Ask them:
- What they ask the security team in the first hour.
- How they assess the risk to individuals, and whether they recommend notifying the authority and possibly informing the people affected.
- What they record in the breach register, even if notification is not required.
- Which three measures they would request to prevent a repeat.
A strong candidate separates what they know from what they assume and can explain their recommendation to management in a few sentences. Have the CISO or a member of the security team take part: the quality of the conversation between them is a signal in itself. To build the full process, rely on our method to assess cybersecurity skills.
Common mistakes
- Appointing a DPO without resources: a DPO with no time, no budget and no access to management does not meet GDPR requirements and is of little use in a crisis.
- Choosing on qualifications alone: an excellent lawyer can be lost in a data breach if they have never worked with a technical team.
- Ignoring conflicts of interest: naming the head of IT or the CISO as DPO for convenience exposes the organisation.
- Forgetting the formalities: the DPO's contact details must be published and communicated to the supervisory authority.
- Isolating the DPO: without a regular meeting with the CISO and IT, each side learns about the other's issues too late.
- Underestimating pay: it varies with the sector, the sensitivity of the data and the scope of the role. Profiles combining law and security are rare, so set a realistic range from the start.
In short
A good DPO protects people, and does it better when they understand the security of the systems that process their data. To hire one, draw the line with the CISO and the GRC analyst, choose the talent pool that best complements your team and assess candidates on a simulated data breach rather than a recitation of the regulation.
Looking for a DPO who can work with your security team, or a GRC profile to support them? At Cyber Recrut, a recruiter and a security practitioner scope the role with you, and our shortlisted candidates prove their skills on hands-on labs. See how we work or tell us about your hiring need.