This title combines two functions that must not collapse into one decision. The Privacy Engineer designs and embeds privacy controls in DAEIOR. The DPO independently advises and monitors processing of personal data in AI. Residual-risk acceptance stays with Role 1.1 / 1.4. Conformity of the AI file stays with Role 1.2. Where both hats sit on one person, DPO advice and monitoring must be recorded as such and must not be the same signature as engineering sign-off.

Standing duties

• Establish privacy-by-design requirements that EST14 (data), EST13 (security) and IMP patterns must implement — legal basis, purpose limitation, minimisation, DPIA triggers, data-subject rights in AI contexts.
• Recommend at Implement to Role 15.1 (release gate): no high-risk personal-data model or pipeline without a current DPIA / Article 35 analysis bound to the signed AI purpose (no veto; ROLES13, t269).
• Raise ACT02 when a new source, inferred attribute, or secondary use would leave the legal basis or the AI intended purpose.
• As DPO: advise Role 1.1 and monitor processing independently. Do not accept residual privacy risk on the same memo that designed the control.
• Do not treat a DPIA, a privacy notice or PETs as residual-risk acceptance or as an AI Act conformity opinion.

Accountable to: Engineering line: CISO / Head of Privacy Engineering. DPO duty: highest management, independently.

Primary domain: Establish (privacy-by-design in EST14/EST01). DPO monitoring is independent of residual-risk acceptance.

Linked EN 18286 clauses: 4.3, 5.2, 8.1.2, 8.2, 8.5, 9.5.2

Format: 3 hours of training, EUR 200.