Data Protection Officers: A Comparison of US Law, EU Law, and Soon-to-be-EU Law

Although organizations in the United States have dealt with privacy issues for years, only in the past decade have they begun to view the complexities of privacy as requiring formal organizational structure and, in some cases, one, or more, dedicated employees. While in some organizations “data privacy” and “data security” falls within the ambit of the legal department, other organizations have created offices that are focused solely on privacy issues. There is little commonality in how these offices are staffed, funded, or organized. For example, while some organizations have “Chief Privacy Officers” or “Chief Information Technology Officers” that report directly to senior management, other organizations have privacy officers that report through a General Counsel or to a Chief Compliance Officer. …

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