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Can you incorporate SCCs by reference in a DPA?
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I think it depends on the org, but I would generally say it’s a more senior role. Lower than c-suite or VP from what I’ve seen. Lots of my clients make their DPOs one of their general counsel members or hire an outside DPO
This is consistent with what I have seen and heard.
Senior Director or VP. This is what I’ve seen across most industries.
I’m now a DPO at big law. Director level and in general counsel