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Occupations and Terms of Reference › Data protection officer

Universal terms of reference · POS-017 · version 1.0 · status: draft · next review 2027-10-27

Data protection officer

To make sure patient and staff personal data is protected and lawfully used, and to advise the organisation on privacy risk and data rights.

Each part of this page links to the related trainings, competencies and policies. The links are the same for every facility, so an organisation can see at a glance what a role requires and what it is trained in.

Job description

Job summary. You protect personal data. You advise on lawful processing, run data protection impact assessments, handle data subject requests and breach reporting, and train staff on confidentiality.

Reports to: Chief executive officer; reports directly to the board on data protection matters.

Leads or supervises: No direct reports.

What you do on a typical day

Working conditions and demands

What good looks like

Place in the organogram

Reporting line, from the top: see the organogram on the Occupations page. The lines above and below this role are listed in section 3.

1. Golden rules

These rules apply in every setting.

2. Identification

Item Detail
Position code POS-017
ISCO-08 2529 (skill level 4)
ESCO to map
Department Governance
Facility types Hospital, Ambulatory, Transport, Medevac, Fitness, Aesthetic

3. Reporting line and working relationships

Reports to: POS-003. Supervises: .

Works with Nature of the relationship
Chief information officer Information security and system access.
Legal counsel Data protection law and claims.
Chief quality and safety officer Breach and incident reporting.

4. Key accountabilities

Domain Accountability Evidence of delivery Checked Linked competencies Linked trainings Linked policies Standards
Privacy framework Maintains the data protection policy and framework. Policy reviewed annually Annually C-01 T-04 POL-DATA 1
Impact assessments Runs data protection impact assessments for new systems and projects. Assessments completed before go-live Monthly C-02 T-04 POL-DATA 2
Breaches Leads breach response and makes sure notifications are made on time. Breach register complete; reports within legal timeframe Monthly C-03 T-04 · T-05 POL-DATA · POL-INC 2
Rights and training Handles data subject requests and runs privacy training. Requests answered within timeframe; training compliance Monthly C-01 T-04 POL-DATA 2

5. Decision rights

The post holder decides Consults or escalates
Advice on lawful processing and privacy risk Notifiable breaches (CEO and regulator)
Responses to data subject requests within law Disputes with the regulator (CEO and legal counsel)

6. Qualifications and experience

ID Qualification Mandatory Validity
Q-01 Degree in law, information governance, health informatics or a related field Yes Lifetime
Q-02 Data protection professional certificate (for example, CIPP or national equivalent) Yes Lifetime
ID Experience Minimum years Mandatory
E-01 Data protection, information governance or privacy experience, ideally in health 5 Yes

7. Training requirements

Recommended common practice. Each facility adapts the list to its national law. Essential items apply in every setting; recommended items apply where resources allow.

ID Training Tier When Validity Linked policies Linked competencies
T-01 Facility induction essential at_entry Once POL-WHISTLE · POL-EQUAL · POL-DATA –
T-02 Safeguarding adults essential periodic Every 3 year(s) POL-SAFEG –
T-03 Safeguarding children essential periodic Every 3 year(s) POL-SAFEG –
T-04 Data protection and confidentiality essential annual Every 1 year(s) POL-DATA C-01 · C-02 · C-03
T-05 Incident reporting and open disclosure essential periodic Every 2 year(s) POL-INC C-03
T-06 Governance, accountability and assurance recommended periodic Every 3 year(s) – –
T-07 Emergency and major incident command essential annual Every 1 year(s) POL-INC –
T-08 Speaking up, inclusion and equality leadership essential periodic Every 2 year(s) POL-WHISTLE · POL-EQUAL –

8. Health, fitness and language

ID Requirement Frequency Tier Minimum in low-resource settings
H-03 Fitness-to-work assessment at entry and after serious illness or injury Every 12 months recommended Fitness check at entry
Language Level Mandatory
Official language of the country of practice professional Yes
English working Yes

9. Competencies by level

ID Competency Foundation Practitioner Expert Assessed by Revalidate Linked trainings
C-01 Data protection law and principles Applies data rules Advises on lawful processing Designs the data protection framework Privacy audit Every 12 months T-04
C-02 Data protection impact assessment Identifies data risk Runs impact assessments Sets risk standards for new systems Assessment review Every 12 months T-04
C-03 Breach response and reporting Reports suspected breaches Leads breach investigations Designs breach response across the organisation Breach exercise Every 12 months T-04 · T-05

10. Performance evaluation

ID Indicator Target Data source Frequency
PI-01 Breaches reported within legal timeframe 100% breach register Monthly
PI-02 Impact assessments completed before go-live 100% assessment register Quarterly
PI-03 Data subject requests within timeframe 100% request log Monthly
PI-04 Staff privacy training compliance 100% training records Quarterly

11. Career ladder and promotion

Level Role Minimum experience to move on Qualifications Competency minimums Trainings required Assessment
Executive Data protection officer 5 years (recommended) Q-01, Q-02 C-01 expert, C-03 practitioner T-04 Executive appointment and performance review

12. Policies the post holder follows

Each policy is a standard template that the facility adopts and adapts. Templates are maintained centrally, so every facility works from the same version.

POL-SAFEG · Safeguarding adults and children
Purpose: Protect patients from abuse, neglect and harm, and make sure every concern is recognised and acted on.
Scope: All staff, volunteers and contractors.
Key rules:
  • Recognise signs of abuse and neglect and record them factually.
  • Report every concern to the designated safeguarding lead the same shift.
  • Do not investigate alone.
  • Share information only as the safeguarding procedure allows.
Linked trainings: T-08 · T-09 · Review every 12 months · Template 0.1 (draft)
POL-DATA · Data protection and confidentiality
Purpose: Keep patient and staff information private, secure and used only for care and legal purposes.
Scope: All staff who access records or systems.
Key rules:
  • Access only the records needed for your work.
  • Keep records secure; do not leave screens or paper unattended.
  • Do not share information without a lawful basis.
  • Report any breach to the data protection officer within 24 hours.
Linked trainings: T-10 · Review every 12 months · Template 0.1 (draft)
POL-WHISTLE · Speaking up (whistleblowing)
Purpose: Let staff raise patient safety or conduct concerns without fear of reprisal.
Scope: All staff.
Key rules:
  • Raise a concern with your line manager or the named speaking-up officer.
  • If that route fails, escalate to the board or the national regulator.
  • Retaliation against anyone who speaks up is a disciplinary offence.
  • Concerns are recorded, investigated and the outcome given to the person raising them.
Linked trainings: T-01 · Review every 12 months · Template 0.1 (draft)
POL-EQUAL · Equality, diversity and inclusion
Purpose: Give every patient and colleague fair access, respectful treatment and reasonable adjustments.
Scope: All staff and patients.
Key rules:
  • Treat every person with dignity regardless of background.
  • Make reasonable adjustments, including interpreters, for language and disability.
  • Report discrimination through the speaking-up route.
  • Monitor access and outcomes by group.
Linked trainings: T-01 · Review every 24 months · Template 0.1 (draft)
POL-INC · Incident reporting and open disclosure
Purpose: Report and learn from incidents and near misses, and tell patients honestly when things go wrong.
Scope: All staff.
Key rules:
  • Report every incident and near miss the same shift.
  • Give the patient and family an honest account and an apology where appropriate (open disclosure).
  • Take immediate action to protect others.
  • Learn: contribute to the review and follow the agreed actions.
Linked trainings: T-11 · T-05 · Review every 12 months · Template 0.1 (draft)

13. Standards that name this role

1 · 2

14. Record history

Date Change Approved by
2026-10-27 Draft record, batch 1 of the position build Awaiting approval

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