Under the PDPL, a Data Protection Officer is required where an organisation's core activity involves large-scale, regular and systematic monitoring of individuals. Biometric time and attendance systems and occupational health monitoring place most manufacturers inside that trigger, and the law allows that DPO to be an internal hire or an external provider, a decision most industrial compliance functions have not yet made formally.

Why manufacturing needs a dedicated DPO

  • Biometric time and attendance systems and occupational health records that meet the PDPL's systematic monitoring trigger
  • Industrial IoT and connected production systems increasingly capturing operator and site personnel data
  • Multi-tier supplier and distributor networks exchanging personal data under existing commercial contracts
  • Cross-border data flows tied to group reporting or international parent companies

What this looks like in practice

Plant-level operations rarely have spare capacity to build and staff a dedicated privacy function. RSM's DPO as a Service provides that accountable owner without disrupting production. We act as your registered point of contact for SDAIA engagement, manage data subject access requests from workforce and supplier stakeholders, maintain DPIAs for high-risk workforce technology such as biometric access control, and run breach response tested against the 72-hour notification requirement.