What this control covers

Formally appoint a Data Protection Officer (or designated contact person) through a board/management-level decision. Define the DPO's role, responsibilities, and reporting line. For SDFs, ensure the DPO is India-based and directly accountable to the board. Publish DPO contact details prominently on the website and application. Include DPO details in all DSAR responses. Objective: Establish an accountable, named contact for data principal queries, regulatory communications, and grievance redressal.

Why it matters

Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.

How to implement

AWS

Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.

Azure

Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.

GCP

Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.

Google Workspace

Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.

On-premises

Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.

Evidence to collect

  • policy_document — A signed, version-controlled policy stating leadership intent and the named owner.

Signed policies, procedures, and registers document the safeguard. Focus: Data Protection Officer (DPO) Appointment & Publication.

Quick checklist

  • Define — Data Protection Officer (Dpo) Appointment / Publication
  • Ensure — Data Protection Officer (Dpo) Appointment / Publication
  • Designate — Data Protection Officer (Dpo) Appointment / Publication

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