Privacy Officer

Functieomschrijving:

The Privacy Officer is responsible for ensuring the organization's compliance with the

General Data Protection Regulation (GDPR) and the Dutch Algemene Verordening

Gegevensbescherming (AVG).

This role includes managing data protection strategies, overseeing data processing

activities, and ensuring personal data is handled according to both GDPR and AVG

requirements. The Privacy Officer will collaborate with various departments, mitigate

privacy risks, implement data protection policies, and manage data breaches.

Additionally, the Privacy Officer may serve as the organization’s Functionaris

Gegevensbescherming (FG), acting as the internal data protection officer.

Key Responsibilities

1. GDPR and AVG Compliance Management

• Develop, implement, and maintain a comprehensive GDPR and AVG compliance

program.

• Regularly audit data processing activities to ensure adherence to both GDPR and

AVG regulations.

• Advise the organization on its obligations under GDPR and AVG and assist in

developing relevant data protection policies.

2. Data Protection Impact Assessments (DPIA)

• Conduct and oversee DPIAs for new projects and data processing activities that

may pose high risks to individuals' rights and freedoms under GDPR and AVG.

• Collaborate with project teams to mitigate risks identified during DPIAs.

3. Data Subject Rights Management

• Manage and respond to data subject requests under GDPR and AVG, including

access, rectification, erasure, restriction of processing, and data portability

requests.

• Ensure responses to data subject requests are handled within legally required

timelines.

4. Training and Awareness• Develop and deliver GDPR and AVG-related training programs for employees to

promote awareness of data protection obligations.

• Ensure that all staff are informed of their responsibilities under GDPR, AVG, and

other relevant data protection laws.

5. Data Breach Management

• Establish and maintain a data breach response plan.

• Manage data breach incidents in compliance with GDPR and AVG, including

notification to relevant authorities within 72 hours and communication with

affected individuals as required.

• Document all data breaches and corrective actions taken.

6. Liaison with Supervisory Authorities

• Act as the point of contact for the organization with supervisory authorities,

including the Dutch Autoriteit Persoonsgegevens (AP).

• Prepare and submit required documentation and reports to supervisory

authorities under GDPR and AVG.

7. Policy Development and Enforcement

• Draft, review, and update the organization’s data protection policies and

procedures to ensure they comply with GDPR and AVG.

• Ensure policies are enforced and regularly updated in line with changes in GDPR,

AVG, and other data protection regulations.

8. Vendor and Third-Party Management

• Assess and ensure that third-party vendors and partners comply with GDPR and

AVG requirements.

• Negotiate and manage data protection agreements (DPA) with vendors.

9. Record Keeping

• Maintain up-to-date records of all data processing activities as required by GDPR

and AVG.

• Ensure that these records are easily accessible and available for review by

supervisory authorities.

• Functionaris Gegevensbescherming (FG) Responsibilities• Internal Data Protection Officer (DPO): Serve as the Functionaris

Gegevensbescherming (FG) if designated, acting as the organization's Data

Protection Officer under Dutch law.

• Independent Oversight: Ensure independent oversight of the organization’s data

protection practices, providing unbiased advice and guidance.

• Reporting: Report directly to the highest management level within the

organization on GDPR and AVG compliance matters.

• Consultation with AP: Consult with the Dutch Autoriteit Persoonsgegevens (AP)

on complex data protection issues, especially when DPIAs indicate high risks.

Key Deliverables (GDPR & AVG Compliance)

1. Data Processing Records: Maintain comprehensive and up-to-date records of all

personal data processing activities as required by GDPR and AVG.

2. Data Protection Impact Assessments (DPIA): Conduct DPIAs for high-risk

processing activities and document findings and mitigation strategies in line with

GDPR and AVG requirements.

3. Data Breach Reports: Document all data breaches, including the nature of the

breach, affected data, corrective actions taken, and notifications to authorities

and data subjects under GDPR and AVG.

4. GDPR and AVG Training Programs: Develop and deliver ongoing training programs

for employees to ensure awareness of GDPR, AVG responsibilities, and data

protection best practices.

5. Data Subject Request Responses: Ensure timely and accurate responses to data

subject requests under GDPR and AVG within the legally required timelines.

6. Third-Party Data Protection Agreements: Ensure that all third-party vendors

processing personal data have valid data protection agreements in place and

comply with GDPR and AVG requirements.

7. Compliance Reports: Regularly report to senior management and, where

applicable, to the board of directors on the status of GDPR and AVG compliance,

risks, and any incidents

Eisen:

Required Skills

• In-depth Knowledge of GDPR and AVG: Comprehensive understanding of both

GDPR and Dutch AVG, including data protection laws and privacy regulations.

• Analytical Skills: Ability to assess and mitigate risks related to data privacy and

security under GDPR and AVG.

• Communication Skills: Strong verbal and written communication skills in both

Dutch and English to effectively convey GDPR and AVG requirements to

stakeholders.

• Project Management: Capable of managing multiple projects simultaneously

and ensuring timely compliance with GDPR and AVG.

• Attention to Detail: High attention to detail for managing data records,

conducting DPIAs, and handling data subject requests.

Desired Experience

• Education: Bachelor’s degree in Law, IT, Compliance, or related fields. A

master’s degree or certification in data protection (e.g., CIPP/E, CIPM) is

preferred.

• Experience: At least 3-5 years of experience in data protection, privacy, or a

related compliance role, with specific experience in the Dutch market.

• Industry Experience: Experience working in industries with high data protection

standards, such as finance, healthcare, or technology, is advantageous.

• Regulatory Interaction: Experience interacting with regulatory bodies, such as

data protection authorities, especially the Dutch Autoriteit Persoonsgegevens, is

preferred.