Under the PDPL, a Data Protection Officer is required where an organisation's core activity involves large-scale, regular and systematic monitoring of individuals or the core processing of sensitive data. Continuous transaction monitoring, credit scoring and biometric authentication place most banks, insurers and financial services firms squarely inside that trigger, and the law allows that DPO to be an internal hire or an external provider. Few financial institutions have resolved which model fits, or resourced the role properly under either choice.

Why financial services needs a dedicated DPO

  • Continuous transaction monitoring and credit scoring that meet the PDPL's systematic monitoring trigger for mandatory DPO appointment
  • Biometric authentication and KYC processing that constitute core processing of sensitive data, a second independent trigger
  • Regulatory correspondence currently split across legal, compliance, risk and IT, with no single named individual accountable to SDAIA
  • Rising customer data subject access requests with no designated owner tracking them against statutory timelines

What this looks like in practice

An in-house DPO carries institutional knowledge but is costly to hire and retain, and leaves a single point of failure. RSM's DPO as a Service gives you that designated accountable function from day one, backed by a full advisory team rather than one individual. We act as your registered point of contact with SDAIA and NDMO, manage data subject access requests at retail transaction scale, run breach response tested against the 72-hour notification requirement, keep a living RoPA and DPIAs current against your banking and payments data, and embed privacy review into new products and vendors before launch.