Privacy Officer

A Privacy Officer is the official within an organization who oversees compliance with the General Data Protection Regulation (GDPR) and other privacy laws. This person advises management on privacy risks, verifies that personal data is processed in accordance with the rules, and serves as the point of contact for the Dutch Data Protection Authority and data subjects. For certain organizations, appointing a Privacy Officer is required by law, for example, in cases of large-scale processing of special categories of personal data or systematic monitoring of behavior.

What tasks does a Privacy Officer perform?

The Privacy Officer has three core roles. First, he advises the company on privacy issues: what data you’re allowed to collect, how long you’re allowed to retain it, and how to safeguard the rights of customers or employees. Second, he conducts internal audits to verify that departments are complying with the GDPR. This includes checking whether consent forms are correct, whether data breaches are reported, and whether data processing agreements with suppliers are in order. Third, the Privacy Officer acts as a liaison between the organization and external parties such as the Dutch Data Protection Authority or individuals exercising their right of access. He records processing activities, coordinates data breach registrations in accordance with AP guidelines, and ensures that reports are submitted within 72 hours.

Why the Privacy Officer Has Become Indispensable Since 2018

With the introduction of the GDPR in May 2018, European lawmakers significantly tightened data protection requirements. Fines can reach up to 20 million euros or 4% of global revenue, which poses an existential risk even for small and medium-sized enterprises (SMEs). Organizations that routinely process personal data must be able to demonstrate accountability. The role of Privacy Officer emerged in response to this accountability requirement: an independent position that not only monitors but also advises. Whereas privacy matters used to be scattered across IT, HR, and legal departments, the Privacy Officer now consolidates knowledge and authority. For ecommerce stores, healthcare institutions, recruitment agencies, and other data-driven companies, this role has now become standard.

What a Privacy Officer Brings to Small and Medium-Sized Businesses

An effective Privacy Officer prevents fines, but delivers even more value. They help translate your business strategy into clear privacy processes: what customer data you collect and for what purpose, how long you retain it, and how you transparently inform customers. This increases customer trust and strengthens your reputation. In addition, the Privacy Officer identifies risks early on, for example when selecting a new CRM tool or setting up a newsletter. At Monkey Vision , we often integrate privacy considerations into SEO initiatives and web design projects: a cookie banner that works correctly, a privacy policy that’s easy to find, and consent mechanisms that don’t block conversions but actually support them.

The Privacy Officer plays a role in a wide range of business processes. Below are four specific situations in which small and medium-sized enterprises (SMEs) utilize this role, plus a decision-making guide to help determine when appointment is mandatory and when it is not.

Data breach registration and mandatory reporting of incidents

If an employee accidentally sends an email containing customer data to the wrong recipient, or a laptop with patient records is stolen, you must assess within 72 hours whether a report to the Dutch Data Protection Authority is required. The Privacy Officer coordinates this process: they identify which data has been leaked, assess the risk to those affected, draft the report, and notify affected individuals if necessary. In practice, we often see with SMB clients that data breaches are not recognized until it is too late because there is no clear process in place. A Privacy Officer provides an internal reporting form, trains employees to identify incidents, and maintains a register. This register is mandatory and is immediately requested during inspections. Without a Privacy Officer, this record-keeping often falls behind or is completely missing.

Data processing agreements with suppliers and partners

Any external platform that processes personal data on your behalf—from your email marketing tool to your accounting software—requires a data processing agreement. The Privacy Officer verifies whether these agreements exist, whether they comply with GDPR requirements (Article 28), and whether the suppliers themselves are also compliant. For an ecommerce store with ten external integrations—from a payment provider to a shipping partner—this can mean dozens of contracts. The Privacy Officer manages this overview, identifies missing agreements, and negotiates with suppliers as needed. Many small and medium-sized businesses discover during a website redesign or migration that their current setup is not in order. The Privacy Officer resolves these issues in advance so that you do not face any privacy risks when the site goes live.

Requests for access and exercise of data subject rights

Customers, job applicants, or website visitors may exercise their rights: access to their data, correction, deletion, or data portability. The Privacy Officer processes these requests within the statutory one-month deadline. He gathers the data from various systems, assesses whether any exceptions apply, and communicates with the requester. For a recruitment agency with thousands of resumes in its system, a single request for access can mean hours of work. The Privacy Officer automates processes where possible, creates templates, and trains colleagues on proper handling. Without this coordination, deadlines are missed and legal risks arise. In practice, we see that companies without a Privacy Officer often only discover that their process is flawed after a complaint is filed with the AP.

Privacy by design for new products and services

When you launch a new e-commerce feature, build a customer portal, or start a marketing campaign with personalized content, you must assess in advance what privacy risks this entails. The Privacy Officer conducts a Data Protection Impact Assessment (DPIA): they identify what personal data you collect, why it’s necessary, how you secure it, and whether there are alternatives with lower privacy risks. At Monkey Vision , we often involve our clients’ Privacy Officers as early as the wireframe phase of a web project. This prevents you from having to rebuild a cookie banner or adjust a consent flow after delivery. Privacy by design saves on reprogramming work and improves the quality of your final product.

When a Privacy Officer Is the Right Choice—and When It Isn’t

A Privacy Officer is required by law if you work for a government agency, conduct large-scale monitoring (such as tracking platforms or security cameras), or routinely process special categories of personal data, such as medical records or criminal records. For many small and medium-sized businesses, appointing a Privacy Officer is not mandatory, but it is advisable as soon as you work with customer data more than just occasionally. An ecommerce store with 5,000 customers, a consulting firm with CRM data, or an event organization that sells tickets would benefit from having a Privacy Officer, even if only on a part-time or freelance basis. When is it not necessary? If you only manage contact information for a few dozen clients without automated processing, a privacy statement and a simple processing register are often sufficient. Consider conducting a privacy audit first to determine whether the role is necessary.