The world only has about 18 months to find 75,000 data protection officers (DPOs).
According to the International Association of Privacy Professionals (IAPP), that's how many DPOs it will take to meet the mandates of the European Union's General Data Protection Regulation (GDPR) which goes into effect in May 2018 -- and two-thirds of them won't even be inside the EU.
The rigorous new privacy and security regulation mandates that public authorities and some companies must have a DPO, who is, by law, independent from the organization that funds the position. Data "controllers" or "processors," must designate a DPO if they conduct "regular and systemic monitoring of data subjects on a large scale," or if they do "processing on a large scale of special categories of data."
"Appointing a data protection officer is just the beginning," said IAPP VP of research and education Omer Tene, in a statement. "Organizations will need to ensure DPOs are well qualified and trained in the growing body of knowledge of the privacy profession, including law, technology and data management best practices.”
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The DPO requirement is just one of many components of the GDPR, which is much fiercer than earlier laws protecting European citizens' data privacy or any privacy laws in the US. The limitations on data use are stricter, the penalties for noncompliance are steeper, and the number of organizations that will have to comply are more numerous. For example, it's estimated that twice as many American companies will have to comply with GDPR than complied with the now-defunct Safe Harbor.
IAPP estimates that 9,000 US organizations will have to have a DPO to comply with the GDPR mandate. (More than just that 9,000 will have to comply with lesser elements of the law.) As the EU's largest trading partner, the US will need the most DPOs, but not far behind is China (7,568). Switzerland (3,682), Russia (3,068), and Turkey (2,045), which also need thousands apiece.
This demand for data protection officers, however, may not actually create new jobs. Nine out of 10 IAPP members surveyed said they would reassign an existing internal employee to take this position -- either making their current head of privacy the DPO or training someone else to do it.
The authors of the report acknowledge, however, that there may be a bias in this survey, because the respondents are already members of a privacy professionals organization, and thus their organizations' privacy departments are relatively mature.
Mature or not, a separate GDPR readiness study released today by AvePoint and CIPL found that most organizations have a lot of work to do between now and May 2018. Three-quarters of organizations do not yet comply with the new GDPR requirements about consent (users granting consent for how data controllers and processors can use their personal data); 44% do not have procedures in place to identify and tag personal data, sensitive data, or other confidential information; and 39% of organizations do not understand the full lifecycle of the personal data that they hold.
Nearly half of the respondents to the AvePoint/CIPL survey still have not yet decided if they will increase staff or budget to handle new GDPR requirements. Thirty percent have determined they will not invest in any new resources. However, 22.7% reported they were increasing headcount, 20.6% increasing internal budget, and 16.3 % adding external counsel budget.