Data Protection Officer

A Data Protection Officer is expected to be available to handle problems with data destruction. Therefore, in the base configuration, there is a Data Protection Officer role to which users can be assigned.

Data Protection Officer permissions

In the base configuration of PolicyCenter, the Data Protection Officer role has two permissions, requestcontactdestruction and editobfuscatedusercontact. A user named DataProtection Officer with login dpofficer, which has the Data Protection Officer role, is available in the sample data.

In the base configuration, PolicyCenter screens prevent a user from editing obfuscated user contacts if the user does not have permissions to do so. In addition, PolicyCenter prevents a user without the correct permissions from adding obfuscated user contacts to or removing them from groups and roles. You can create additional permissions and configure PolicyCenter to further limit editing of obfuscated objects.

Notifying the data protection officer

The PersonalDataDestruction plugin interface provides a method that enables notification of the Data Protection Officer, notifyDataProtectionOfficer.

In the base configuration, the class that implements the PersonalDataDestruction plugin interface, PCPersonalDataDestructionPlugin, overrides the notifyDataProtectionOfficer method and notifies data protection officers when a destruction request has failed.

The action performed by the notifyDataProtectionOfficer method is defined in the class NotifyDataProtectionOfficerVisitor. This class creates an activity that uses the activity pattern personal_data_destruction_error and assigns the activity to each user present in the system that has the Data Protection Officer role. If no users are found with the Data Protection Officer role, in the base configuration, an exception is thrown.

Note: PolicyCenter can purge retired pinnable roots from the system. However, if there are any issues that occur while purging this data, an activity will be created against the retired root. This activity will be listed in the user interface for users with the Data Protection Officer role. However, the user will not be able to view the details of the activity because the root is retired.