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 site access and continuous workforce health and safety monitoring place most operators and service companies inside that trigger, and the law allows that DPO to be an internal hire or an external provider. Most operators have not formally resolved either question.

Why oil and gas needs a dedicated DPO

  • Biometric site access and continuous workforce health monitoring that meet the PDPL's systematic monitoring trigger
  • Joint venture structures and international operator partnerships creating cross-border personal data flows
  • Extensive contractor and vendor networks handling employee and site personnel data
  • Operational technology, including connected field devices, increasingly capturing data linked to identifiable individuals

What this looks like in practice

A single accountable owner is hard to establish across a workforce spanning permanent staff, rotating contractors and joint venture partners. RSM's DPO as a Service gives you that owner without adding to HR, legal or HSE headcount. We act as your registered point of contact with SDAIA and NDMO, manage workforce data subject access requests against regulatory timelines, maintain DPIAs for high-risk activities such as biometric access control, and run breach response tested against the 72-hour notification requirement.