Mundlak & Birnhack on Process-based Data Protection Law & the DPO

Guy Mundlak and Michael Birnhack (Tel Aviv University – Buchmann Faculty of Law) have posted Toward Process-based Data Protection Law: The Emergence of DPO as a Profession (DPLICIT 2026, forthcoming) on SSRN.  Here is the abstract:

The study documents the recent emergence of DPO (data protection officer) as a quasi-profession in Israel, triggered by the European General Data Protection Regulations (GDPR). Foreign, process-based requirements to appoint a DPO, combined with a study of intra-organisational power resources in ongoing negotiations over compliance, highlight the potential benefits of requiring professionals to adapt and promote legal norms within organisations, but also their risks. In-depth interviews with privacy experts in Israel, three years after the entry into force of the GDPR, help in understanding their role in negotiations over compliance within organisations and evaluating their impact.

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