Data Protection Officer

The Digital Personal Data Protection Act defines a "Data Protection Officer" as a specific individual who is appointed to fulfill this role. According to the text, this appointment is made by a "Significant Data Fiduciary," which is a specific category of Data Fiduciary recognized under the Act. The definition points directly to clause (a) of sub-section (2) of section 10 of the Act. This means that under the Act, the title of Data Protection Officer is strictly tied to individuals appointed under that exact provision. Because the definition is tied directly to this section, the formal title under the Act is limited to those appointed by a Significant Data Fiduciary. This means the term is not used in the Act as a general job title for anyone working in data privacy. Instead, it is a formal statutory role that exists specifically within the framework of a Significant Data Fiduciary's obligations. The text explicitly requires the Data Protection Officer to be an "individual," meaning a corporate entity, an external agency, or an automated system cannot hold this specific statutory title.

Key points

• A Data Protection Officer must be an individual. [Section 2(l)]
• The individual is appointed specifically by a Significant Data Fiduciary. [Section 2(l)]
• The definition is directly tied to the appointment requirements under Section 10(2)(a) of the Act. [Section 2(l)]

Common misreadings

• Assuming that any company or agency can act as a Data Protection Officer, when the text explicitly states it must be an individual.
• Believing that any Data Fiduciary can appoint a statutory Data Protection Officer under this definition, when the text restricts this specific defined role to appointments made by a Significant Data Fiduciary.