Privacy officer responsibilities under Law 25

Law 25 requires you to designate a person responsible for the protection of personal information: the privacy officer. In an SMB, this is often the owner or a manager who carries the role part time. The trap? Having a name on the policy, but an email inbox nobody reads.

Designation and publication requirement

You must officially designate a privacy officer and make their contact details accessible: on your website, in your privacy policy, and, where applicable, in your communications with individuals.

Key point: a generic, unmonitored email address ("info@") is a weakness if nobody handles access, rectification, or consent withdrawal requests within the required deadlines.

Key tasks of the privacy officer

• Governance: oversee internal and external policies, the processing register, and vendor contracts.
• Incidents: coordinate analysis, documentation, and, if required, notification to the CAI and affected individuals (see privacy incident procedure).
• Individual rights: respond to access, rectification, or consent withdrawal requests within the required deadlines.
• Projects: trigger a PIA when a new system or data sharing presents a high risk.
• Awareness: ensure employees understand their responsibilities (see employee training).

Avoid a "paper-only" role

1. Written mandate: scope, escalation authority, time allocated (even half a day per month counts).
2. Quarterly review: vendors, incidents, website updates.
3. Written records: emails, registers, committee decisions to demonstrate reasonable diligence.
4. Clear delegation: execution can be delegated; ultimate accountability stays at the leadership level.

However, delegating without a mandate or budget recreates the ghost role. Give the privacy officer real leverage: access to contracts, incidents, and digital projects.

In practice: the privacy officer does not have to be a full-time IT expert or lawyer. They are the accountable point of contact who connects the law, operations, and the public website.

In brief

• Official designation + published contact details (website, policy).
• Monitored email for individual requests, not a dead generic inbox.
• Governance, incidents, rights, high-risk projects, training: the core of the mandate.
• Written mandate, quarterly reviews, and records: avoid a "paper" privacy officer.

Useful references

• CAI, Privacy officer: role and expectations for organizations.
• Act P-39.1 (private sector): designation and publication requirement.
• 7-step action plan: where to place the privacy officer in an SMB roadmap.

This text is for information only and does not constitute legal advice. For a decision that binds your organization, consult the CAI and a legal professional.

Check your website

Privacy officer contact details must be findable on the public site, with an up-to-date policy. Our free technical scan helps spot observable gaps. It complements, but does not replace, your compliance program.