DPO as a Service For Financial Services
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DPO for Financial Services
Data Privacy Services provides skilled and experienced data protection professionals for many financial services based organisations. We provide the advice and guidance needed for financial services organisations to be compliant.
- Certified DPO
- Meet Legal Requirement
- Reduce Compliance Risk
- Data Breach Support
- DSAR Support
- Flexible Contract Terms
Note – we specifically specialise in Artificial Intelligence (AI) and how this must be implemented taking into account data protection legislation.
Role of a DPO
A DPO ensures that you meet a specified legal requirement and acts as the point of contact for all data protection requirements.
A DPO’s role includes the review and on-going monitoring of compliance with the data protection legislation.
This typically means that the DPO will complete an annual audit of the organisations compliance and develop and maintain a Privacy by Design Plan.
As part of the compliance monitoring activities the DPO will review how Privacy by Design is implemented into the businesses operational processes and procedures.
This is a specific requirement under Article 25 and must be in place to be compliant.
The DPO should act as the central point of contact for any data breach that occurs within the organisation (assuming this involves personal data).
The DPO should have the experience needed to follow the legal and best practice methodology for managing incidents. They will provide advice and guidance and ensure that the correct steps are taken to minimise risk.
Note – they will also be the point of contact with the associated Information Regulator (e.g. the UK’s Information Commissioners Office). We can also act as the liaison point of contact with the Financial Conduct Authority (FCA) with regards to their data protection requirements.
The DPO is required to keep an up-to-date record of the processing (ROPA) of the personal data that the business processes as a Data Controller and Data Processor (this is important when processing the data relating to financial clients).
The ROPA is a legal requirement under Article 30.
Data Subject Access Requests (DSARs) are commonly requested by individuals (i.e. the Data Subject) when exercising their rights under data protection legislation.
The DPO must ensure that the requests are appropriately managed in accordance with the legislative requirements.
A DPO should provide training to all staff and contractors on matters of both data protection and information security awareness.
There are specific legal requirements to train staff (under both Articles 5 and 32) so the DPO must ensure that this is in place and is fit for purpose.
Article 27 of the EU and UK GDPR requires that organisations provide a geographically located representative for citizens of the EU and UK.
UK Representative
This applies when an organisation is based in one region (i.e.the EU) and they process UK citizens data.
In this case, the UK representative must have an office in the UK.
EU Representative
This applies when an organisation is based UK and they process EU citizens data.
In this case, the EU representative must have an office in the EU.
So, in the case of a financial services company this applies if you have workers, contractors or partners that reside for at least part of the year inside the EU.
Note – We have offices in both the UK and EU and can support this requirement.
Other Services
Ask about our free GDPR audit
Processing of personal data within Financial Services
There are some specific requirements to consider when processing personal data within this type of business.
The FCA have guidelines on data protection that they mandate financial services organisations to abide by.
For example, they mandate compliance as pert of their due-diligence of financial services organiations.
Many financial services organisations have challenges in relation to their data processing arrangements and their classifications under the legislation. For example, wealth management and the handling of customer data.
We provide direct support for the development Data Processing Agreements and support the development of data protection and information security clauses within Master Service Agreements.
Businesses have many different software requirements, all of which need to conform with data protection.
Systems such as:
- CRM solutions
- HR solutions
- Finance solutions
- Sales and Marketing solutions
- Operational software solutions
- Web applications
- Bespoke financial platforms
The use of the above software will need to have the appropriate risk assessments and compliance measures in place.
Many financial services organisations have to process sensitive (special categories) data about clients.
Note – this means that some financial services based organisations have a legal requirement to appoint a DPO.
Typically, this is done under the basic requirements of providing the service but the correct legal basis for processing and other requirements need to be followed.
Data Privacy Services are experienced in managing complex software data protection challenges where there is significant sensitive information that is processed during the use of the software.
Also, Data Privacy Impact Assessments (DPIA) are required under the legislation for all of this category of processing.
In terms of data protection, children under the age of 13 have to be treated differently than those aged 13 and over.
This causes significant complexity for some financial services organisations and the way that the legal basis for the processing is obtained must be in compliance with the legislation.
Note – there are also additional transparency requirements if the processing of children’s data is undertaken.
There are crucial rules to follow with regards to how businesses communicate and manage the legal the basis for processing in areas such as:
- Newsletters / SMS
- Media usage (e.g. images, CCTV etc)
- Social media
- Marketing communications
- General photography in and around the establishment
Financial services organisations process personal data of a wide variety of individuals also known data subjects.
These include:
- Customers
- Children of customers over the age of 13
- Children under the age of 13
- Suppliers
- Prospects
- Employees
There are numerous policies and procedures that must be in place in order for the organisation to be compliant.
Also, these documents must be broadly communicated, understood and implemented to demonstrate compliance.
All financial services organisations must be doing everything they possibly can to secure the integrity, confidentiality and availability of personal data.
This requirement is complex and must be fully assessed as to what is required for compliance.
Note – this also includes due-diligence on your supplier network.
We are experts in guiding financial services organisations on the best approach to comply with this area of compliance.
Many financial services organisations are incorporating AI into their software solutions and also into their own business operations.
The rules around AI adoption and data protection are increasing and becoming more complex. We can guide you through the requirements and complete the necessary compliance deliverables.
All financial services organisations need to ensure that they are compliant the requirements of the Digital Operational Resilience Act (DORA).
We can support your review of the requirements and the implementation of any compliance gaps.
Current Incentives
We are offering discounts of 10% for 6 month contracts paid up front of 15% for 12 month contracts paid up front
DPO Service Levels
Premium
- Dedicated DPO
- Registration of DPO with the ICO
- 16 Hours Per Month
- Free Data Protection Audit
- Free ROPA Development
- Free Data Protection Policy
- Free Information Security Policy
- Privacy by Design Monitoring
- UK & EU Representation
- Access to Customer Portal
- Data Breach Support
- DSAR Management
- Monthly DPO Meeting
- Data Protection and Security Training
- Premium Dark Web Monitoring
- Reduced Hourly Rates
Enhanced
- Dedicated DPO
- Registration of DPO with the ICO
- 6 Hours Per Month
- Free Data Protection Audit
- Free ROPA Development
- Free Data Protection Policy
- Free Information Security Policy
- Privacy by Design Monitoring
- UK & EU Representation
- Access to Customer Portal
- Data Breach Support
- DSAR Management
- Monthly DPO Meeting
- Data Protection and Security Training
- Premium Dark Web Monitoring
- Reduced Hourly Rates
Standard
- Dedicated DPO
- Registration of DPO with the ICO
- Free Data Protection Policy
- Access to Customer Portal
- Access To Data Breach Support
- Access To DSAR Management
- Standard Dark Web Monitoring
- Reduced Hourly Rates
No fixed term contract, discounts are available off the stated prices
Benefits of engaging an outsourced DPO
We are an affordable and cost-effective option
There are many reasons to outsource the DPO function within your business, e.g.
Avoiding a conflict of interest – there are legal requirements regarding the DPO and the potential for conflict of interest. That said, typically a business owner, wealth manager, trader or functional head cannot perform the function of a DPO. So engaging a DPO from Data Privacy Services removes this as an issue.
It’s rarely a full-time role – the DPO role isn’t often required to be a full time role within most businesses. Outsourcing to us enables you to engage a part-time DPO on a flexible working arrangement.
The DPO has to be qualified and experienced – this is a challenging requirement for most organisations to fulfill. Employing an experienced certified DPO will put a significant additional cost to your operating overheads. Engaging one of our DPO resources is far more affordable and cost-effective.
You can call on additional resources – Data Privacy Services has a number of DPOs and also additional professional consultants who specialise in other areas such as information and cyber security.
We also provide you with additional services – these include training courses, online portal and Dark Web monitoring services. You will also be able to access some of our information and cyber security solutions to ensure that you can protect your personal data.
Our Certifications
