Ideal Data Protection Team for an Effective Privacy Function
What would an effective data protection team look like? This post explores my ideal structure based on real organisational needs and practical experience working alongside the roles that best support and strengthen a Data Protection Officer or privacy lead.
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Why Data Protection Team Structure Matters
There’s a Bulgarian saying that goes: “A united group can lift a mountain”, which rings very true for a data protection team.
A DPO or a privacy lead can’t achieve compliance on their own. It’s a team effort, without which the DPO just swims againts the tide all the time, getting more and more exhausted, eventually leaving the company. With that, they also leave GDPR compliance management in a poor state.
Foundations: Do You Really Need a Full Privacy Team or Just a DPO?
At some point, organisation realise they need a data protection function - either because the law requires or because data is important to them. This is good, but from my experience, they also think that hiring a DPO will solve all their problems.
Hiring a DPO is the first step towards building an effective privacy function, but definitely not the end.
The Role of the DPO and How to Support It
Not all organisations need a full team. However, if you just have a DPO, you have to be mindful and allow them to do their GDPR tasks, without adding other things to their job specs just because they can do it, it’s convenient, or no one else can do them.
It is not prohibited to add these tasks, of course, as long as there is no conflict of interest. However, the practical problem is that you dilute the DPO role, which means you need other roles to deal with, for example, the operational side of GDPR compliance while the DPO can make the strategic and important decisions, as well as whatever else you added to their to-do list.
In simple terms, you can operate with just a DPO, but only if they are allowed to focus on that role. As soon as their responsibilities expand beyond core data protection, additional support becomes necessary. A data protection manager, for example, can ensure nothing is missed and give the DPO the space to focus on oversight and strategy. Otherwise, your DPO can become jaded.
Building the Privacy Function
Compliance is often seen as something you must do, rather than something more exciting like finding leads and marketing that attracts potential customers. Compliance isn’t “lucrative” like sales is, by comparison, so there is tendency to spend the minimum amount on it so you can say you have ticked a box.
I get that – businesses have to make choices. However, if data is important to the business and customers do care, you can’t have one person (a DPO or another role) to deal with the entirety of it. It looks incomplete and half thought-through.
The value of compliance, however, is that it’s a preventative function. It doesn’t win you money per se but it does save you money and headache, the price on which you will only see when something goes wrong. There is some correlation between how well the privacy team functions and how much you have invested – if there is no united group to lift the mountain, the price tag on mistakes can be high.
What My Ideal Data Protection Team Structure Looks Like
If I could have a team, I would probably call it “Data and Legal”, comprising of:
Data protection: DPO, data protection manager, privacy analyst
Legal: in house IT / data solicitor for the contentious questions, legal pitfalls
Information security: the more technically-oriented people that can advise on security measure in practice and how to embed privacy by design and by default principles in the software development cycle.
Common Mistakes in Data Protection Team Structure
One mistake I have seen is not knowing whether or not you are legally required to have a DPO. This is a simple hurdle to overcome – have a look at Article 37(1) of the UK GDPR. If any of the conditions apply to your organisation, then a DPO is a legally required role.
Another mistake is thinking that the DPO will do it all. The main tasks of the DPO are to monitor and advise; this doesn’t necessarily include literally redacting information to be disclosed in a personal data request.
While a DPO can take on such tasks, organisations should recognise the trade-off. Time spent on operational work reduces the DPO’s ability to focus on strategic planning and long-term compliance. It’s a bit like asking a Finance Director to send out invoices –possible, but not the best use of their expertise.
Practical Steps to Improve Your Privacy Function
If you are interested in improving your data protection team, you should assess:
What personal data your organisation uses - the higher risk it is, the more arms to the team you may need.
The size of your organisation and what various departments do with personal data.
Your regulatory exposure and what this could mean for you financially and reputationally if something went wrong.
What the GDPR work is like – a lot of requests, heavy data sharing, data protection impact assessment, product features, international work?
If you just hired a DPO, could they deal with the above in a meaningful way on their own, ensuring defensible compliance.
If you think they may leave because of the work, it’s likely that you do need more people on the privacy team to divide the work.
Building an effective data protection isn’t easy. There will also be more to do, and the current team will always dream of extra hands on deck.
But the question that makes a difference is whether the DPO/equivalent feels supported, or are just told to get on with it.
Data Protection Team FAQs
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A privacy governance structure defines how data protection responsibilities are organised, managed, and overseen within an organisation. It includes roles, reporting lines, decision-making processes, and how privacy integrates with areas like legal, IT, and risk. A strong governance structure ensures that data protection is not siloed, but embedded into everyday business operations.
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The UK GDPR is silent on team structure, but there are clear expectations around accountability, governance, and independence. In practice, this means combining central oversight (e.g. a DPO) with distributed responsibility across the business (Privacy or Data Champions).
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No, but some organisations choose to appoint one voluntarily. Even where a formal DPO is not required, having a clearly defined privacy lead is essential to manage risk and demonstrate compliance.