Under the PDPL, a Data Protection Officer is required where an organisation's core activity involves processing sensitive data. Medical histories, diagnostic records, genetic and biometric data place virtually every healthcare provider inside that trigger, and the law allows that DPO to be an internal hire or an external provider. Most clinical organisations have not resolved which model fits, or built a role beyond existing confidentiality practice.

Why healthcare needs a dedicated DPO

  • Medical histories, diagnostics, genetic and biometric data that fall under the PDPL's core sensitive-data trigger for mandatory appointment
  • Telehealth and remote monitoring generating new categories of patient data with no defined governance owner
  • Data sharing with insurers and referral networks under arrangements that predate the PDPL
  • Patient-facing access requests and consent withdrawals that need faster, more sensitive handling than a standard corporate process
     

What this looks like in practice

An in-house DPO is difficult to resource given the specialist skill set required alongside clinical demands. RSM's DPO as a Service places that accountable function inside your organisation, backed by a full advisory team. We act as your registered point of contact with SDAIA and NDMO, manage patient data subject access requests with the sensitivity the data requires, run breach response tested against the 72-hour notification window, maintain DPIAs for high-risk processing such as patient monitoring, and embed privacy review into new clinical technology and vendors before they go live.