Under the PDPL, a Data Protection Officer is required where an organisation's core activity involves large-scale, regular and systematic monitoring of individuals. Continuous GPS tracking of drivers and biometric warehouse access place most logistics operators inside that trigger, and the law allows that DPO to be an internal hire or an external provider, a decision most operators have not formally resolved.

Why logistics and supply chain needs a dedicated DPO

  • Continuous GPS tracking of drivers and biometric warehouse access that meet the PDPL's systematic monitoring trigger
  • Extensive subcontractor and third-party carrier networks exchanging personal data across a single shipment
  • Fleet management systems generating continuous location data with no defined retention owner
  • Cross-border shipment and customs documentation requiring SDAIA-recognised transfer safeguards

What this looks like in practice

A distributed workforce of drivers and subcontractors makes a single accountable owner hard to establish internally. RSM's DPO as a Service provides that owner, built to move as fast as your shipments do. We act as your registered point of contact for SDAIA engagement, manage data subject access requests from drivers and customers, maintain RoPA and DPIA oversight across fleet and warehouse systems, and run breach response tested against the 72-hour notification requirement.