When should an organisation appoint a DPO?

 

An organisation should appoint a DPO when required by law or when processing presents sustained, high data protection risk. Schools, as public bodies, are mandated to appoint a DPO under the UK GDPR.

Why this matters

Independence is critical where conflicts of interest exist or risk is high.

Legal triggers for a DPO

  • Large scale monitoring of individuals
  • Large scale processing of special category data
  • Public authority status (schools and Multi-Academy Trusts)

Practical indicators

  • Frequent DPIAs
  • High volumes of SARs
  • Regular incidents or near‑misses
  • Complex, multi‑entity environments (Multi-Academy Trusts)

Evidence of good judgement

  • Clear rationale for appointment (or non‑appointment)
  • Defined scope and independence