Registering a DPO with the Dutch DPA
Did your organisation appoint a DPO? Then you have to inform the Dutch DPA.
This can easily be achieved with the DPO registration and change form. You can not pass on this information by email or telephone.
Responsibility
Registering the DPO with the Dutch DPA is the task of the controller within your organisation. The same goes for ensuring that this information stays up to date. In this way, we will be able to reach your organisation and your DPO (quickly) when this is necessary. For example, if there is a data breach or a complaint.
Is there, for example, a temporary substitution of your DPO? Then you can report this in the explanation field of the registration. There you state who the temporary DPO is and how long you expect this substitution to last.
A DPO may also register themselves or pass on changes. A DPO advises on the privacy policy, but is not responsible for its implementation. That is why we ask you to state the contact details of both the controller and the DPO in the DPO registration and change form.
The email address of the controller and the email address of the DPO may not be the same.
Do you hire a DPO externally? Then fill in the name of that person as well. You are not allowed to fill in ‘TBD’ or similar.
Check and evidence
As soon as your registration, change or cancellation has been processed, the controller and the DPO receive a confirmation mail with the information provided. You can check then if the details are correct. This confirmation mail is proof of your registration, and you can include it in your records.
DPO number
The DPO number you receive is the confirmation of the registration of a DPO with the Dutch DPA. It is not linked to the person acting in the capacity of DPO. If someone else becomes the DPO, the DPO number will remain linked with the organisation.
Registering multiple DPOs
You can register multiple DPOs with the Dutch DPA. In that case, you must state clearly which DPO is the first point of contact for the Dutch DPA. You do this by stating the contact details of the DPO who is the first point of contact in the entry fields of the registration and change form.
You can state the contact details of the other DPOs in the explanation at the bottom of the form. There you can also describe, for example, what the focus areas of the different DPOs are.
If you have already registered a DPO, you can use the same DPO number and choose ‘change of a previous registration’ at the top of the form. Do you register DPOs for the first time? Then you choose the option ‘new registration’.
Additional DPO if Wpol or Wjsg data are processed
It is possible that you process certain personal data that fall under the Dutch Police Data Act (Wpol) or the Dutch Judicial Data and Criminal Records Act (Wjsg). And that, under those Acts, you are obliged to appoint a DPO. The Dutch DPA then assumes that the DPO you have registered with us also supervises processing operations to which the Wpol or Wjsg applies.
You can also choose to appoint an extra DPO for Wpol or Wjsg processing operations. But you are not obliged to do this. If you choose this option, you can supplement your existing DPO registration with the Dutch DPA. You will then keep 1 DPO number for both DPOs.
You register your extra DPO by using our DPO registration and change form and choosing ‘change of a previous registration’. In the explanation at the bottom of the form, you state the name and contact details of the DPO for Wpol or Wjsg processing operations.
Privacy statement of the Dutch DPA
The Dutch DPA has drawn up a privacy statement in which you can read how we handle the personal data of registered DPOs.
In the GDPR you can find more information in Articles 37, 38, 39.