Cybersecurity Policy Report, Luxembourg DPA Reminds Municipalities Regarding DPO Requirements, (Aug 18, 2022)
By Tony Foley
The Luxembourg National Commission for Data Protection (CNPD) has published a reminder to all public bodies, including municipalities, that they have the obligation to appoint a data protection officer (DPO) in accordance with requirements of the European Union's General Data Protection Regulation (GDPR) and the country's implementing law.
According to the reminder, published Tuesday in a press release, the DPO may be either a staff member of the municipality or a natural or legal person external to the municipality. In addition, under Art. 58 of the Law of 1 August 2018 on the organization of the National Commission for Data Protection and the general data protection regime, a municipality also may appoint the government commissioner for data protection as DPO. Finally, under Art. 37(1) of the GDPR, municipalities must communicate the contact details of the appointed DPO to the CNPD.
The press release points out that some municipalities have not yet fulfilled their obligation to appoint a DPO and that it has contacted these municipalities during the month of August to ensure that they meet the requirement.
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