Is it possible to combine DPO and whistleblowing officer roles?

20/04/2023 | IAPP

While data protection and whistleblowing are completely different topics, which have their own separate regulations containing unique aims, purposes, scopes and requirements, they're actually closer than they appear, particularly in practical terms. Following the implementation of the EU Whistleblower Directive in 2021, the task of setting up secure reporting channels was given to data protection officers (DPOs). In light of the fact data protection and whistleblowing processes are carried out by the same unit, is it, therefore, reasonable for companies to combine the DPO and whistleblower roles?

In an article for the IAPP, PBK Technology Compliance and Operational Risk consultant FrantiĊĦek Nonnemann, CIPP/E, compares the commonalities between DPOs and whistleblowing officers, such as their independence and access to top management. However, can the roles be combined without creating conflicts of interests?

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