The Information Commisioner says data controllers (i.e. the Practice) must ensure that:
- the DPO is involved, closely and in a timely manner, in all data protection matters;
- the DPO reports to the highest management level of your organisation, ie board level;
- the DPO operates independently and is not dismissed or penalised for performing their tasks;
- you provide adequate resources (sufficient time, financial, infrastructure, and, where appropriate, staff) to enable the DPO to meet their GDPR obligations, and to maintain their expert level of knowledge;
- you give the DPO appropriate access to personal data and processing activities;
- you give the DPO appropriate access to other services within your organisation so that they can receive essential support, input or information;
- you seek the advice of your DPO when carrying out a DPIA; and
- you record the details of your DPO as part of your records of processing activities.