As many of us don our cosy festive jumpers to celebrate Christmas Jumper Day and try to ward off the cold weather, we take the opportunity to reflect on another, less visible source of protection woven into the fabric of responsible organisations. These are the governance and oversight functions that safeguard data, trust, and accountability.
Among these, the Data Protection Officer (DPO) function, whether fulfilled internally or through an external provider, is one of the most important. It forms not just one barrier, but several integrated layers of defence that shield organisations from regulatory risk, operational disruption, and reputational damage.
In a year where global data breaches cost organisations around $4.44 million on average, and regulators across Europe, the Middle East, Africa, and the U.S. intensified scrutiny on governance failures, these layers of defence matter more than ever. So, as your teams pull on their jumpers and join the festive fun today, it’s worth pausing to ask an important question:
Where does your DPO function sit, and how effectively is it protecting your organisation across the layers that matter most?
Layer one: awareness and risk visibility
Every strong defence begins with understanding. The DPO function builds organisational awareness by identifying risk points, mapping data flows, and helping teams understand where obligations arise. This visibility is critical, particularly when research consistently shows that cybersecurity incidents often involve human or process weaknesses rather than technical failures.
By supporting awareness and clarifying responsibilities, the DPO capability helps reduce avoidable errors and ensures that teams make informed decisions about how they collect, use, and share data.
Layer two: governance and accountability structures
Beyond awareness, organisations need clear governance frameworks that define roles, responsibilities, and escalation paths. The DPO function strengthens this layer by establishing policies, ensuring robust lines of accountability, and embedding privacy or risk considerations into early-stage planning for new tools, services and high-risk initiatives. This is not just good practice; it is increasingly a regulatory expectation as significant regulatory penalties focus on weaknesses in governance rather than purely technical shortcomings. A strong DPO structure helps organisations demonstrate that decision-making processes are transparent, documented, and capable of withstanding regulatory scrutiny.
Layer three: operational resilience
Defence also operates at the day-to-day level. The DPO function contributes to resilience by ensuring documented processes match operational reality. This includes oversight across vendors, data lifecycles, new technologies (including AI), and the regular review of safeguards.
When this layer is functioning well, organisations can identify weaknesses early, avoid unnecessary data exposure, and ensure operational practices align with policy, risk appetite, and compliance standards.
Layer four: incident preparedness and response
No matter how strong the preventive measures, incidents can still occur. The DPO function plays a central role in preparing organisations to act quickly, consistently, and lawfully. This includes coordinating internal teams, assessing potential breach impacts, managing regulatory timelines, and ensuring that lessons learned are fed back into governance and process improvements.
Organisations with established DPO-led incident frameworks respond faster and more effectively, experience fewer negative outcomes, and maintain better continuity under pressure.
Layer five: regulatory defence and external assurance
The final layer is one that many organisations only appreciate once it’s tested. Regulators increasingly examine not only the incident itself, but how well a company can evidence its governance, independence of oversight, and ongoing compliance efforts. A well-positioned DPO function (supported with authority, access, and resources) provides this external assurance. It prepares regulatory documentation, maintains audit-ready records, engages directly with authorities where required, and reduces the likelihood of enforcement.
Positioning the DPO function for maximum protection
A DPO function will only be able operate effectively when it is structurally empowered, independent, and properly integrated across the organisation. It must be free from conflicts of interest and structurally separate from functions that make operational decisions about data use. This independence is a requirement under GDPR and increasingly echoed in global regimes.
Additionally, the DPO function must be strategically placed, with direct access to senior leadership. This is because early engagement with decision makers is critical. When the DPO enters only after decisions have been made, the organisation loses the preventive value of the role. They must also be adequately resourced. Without access to the right level of expertise, information, and cross-functional support, oversight becomes less impactful.
At HewardMills, we specialise in serving as an external, independent DPO for organisations that need expert oversight, regulatory-aligned governance, and enhanced protection against compliance and security risks. Acting as an extension of your organisation, we bring the objectivity, experience, and global regulatory insight required to build strong defence layers, from governance and risk management to incident readiness and regulator engagement. If your organisation is looking to strengthen its compliance posture, enhance governance maturity, or reduce regulatory exposure, HewardMills is ready to step in as a trusted external DPO. Contact us to find out more.
