Under the PDPL, a Data Protection Officer is required where an organisation's core activity involves large-scale, regular and systematic monitoring of individuals, a trigger that loyalty tracking and personalised marketing at scale can bring most retailers into. The law allows that DPO to be an internal hire or an external provider, a decision most retail compliance functions have not formally made.
Why retail and consumer goods needs a dedicated DPO
- High-volume customer tracking through loyalty programmes, e-commerce accounts and point-of-sale systems
- Marketing technology stacks and advertising partners processing customer data for targeting and personalisation
- Cross-border e-commerce and fulfilment arrangements requiring SDAIA-recognised transfer safeguards
- Growing volumes of consumer data subject access requests and marketing opt-outs with no scalable owner
What this looks like in practice
Retail's pace of campaigns and product launches leaves little room to build a dedicated privacy function internally. RSM's DPO as a Service gives you that accountable owner without slowing the business down. We manage data subject access requests and opt-outs at consumer scale, act as your registered point of contact for SDAIA engagement, embed privacy-by-design review into new loyalty and marketing initiatives before launch, and run breach response tested against the 72-hour notification requirement.