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Frank is correct. Most advise, including mine, has been to avoid appointing a formally designated DPO unless required in order to avoid the independence and expertise requirements, as well as the protection from dismissal element. The appointment of a DPO is different from the 'designation' of someone as being responsible for data protection. I would such that all firms appoint one person to be a 'designated person' but would discourage going the extra mile and appointing a DPO if they can help it.

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