Defining the DPO and Consent Manager Roles
The Core Compliance Personnel (DPDPA Sections 10 & 16)
Core Mandate: Dedicated Roles
DPO & CM
The DPDPA introduces two distinct, critical roles: the Data Protection Officer (DPO) for internal compliance, and the Consent Manager (CM) for managing the consent lifecycle.
01
Data Protection Officer (DPO)
Internal Compliance Oversight (Mandatory for SDFs)
The DPO is responsible for overseeing the entire data protection strategy and implementation. They are the **internal point of contact** for management and the **external point of contact** for Data Principals.
IMPERATIVE: Reporting Line
The DPO must report directly to the Board of Directors or highest level of management, ensuring independence and authority to enforce compliance.
02
Consent Manager (CM)
Digital Consent Management Interface
The CM is an entity registered with the DPBI, acting as a single point of interaction to enable the Data Principal to give, manage, review, and withdraw consent through an interoperable, accessible, and transparent platform.
EXECUTION: Technical Integration
Data Fiduciaries must integrate their consent mechanisms to securely receive, track, and act upon consent signals received via registered Consent Managers.
03
Functional Segregation
Clear Distinction in Duties
While the DPO handles overall accountability, the Consent Manager handles the *operational* consent lifecycle, ensuring compliance at the point of interaction with the Data Principal.
Role Comparison:
- DPO: Advises, Monitors, Reports (Internal Focus, SDFs Only)
- CM: Manages Consent, Handles Withdrawal (External Focus, Registered Entity)