Managing the DPO Function Across Multinational Subsidiaries

Successfully managing data protection obligations across a multinational organisation is one of the most challenging functions in the governance landscape today. As data privacy regulations proliferate worldwide, organisations must ensure consistent compliance while respecting regional legal differences and cultural nuances. For those tasked with leading data privacy functions—especially the Data Protection Officer (DPO)—the task is not merely about ticking compliance boxes. It entails fostering a culture of privacy, establishing effective governance frameworks, and navigating cross-border collaborations with diplomacy and precision.

The role of the DPO has become central in helping enterprises uphold data subjects‘ rights, sustain customer trust, and avoid reputational risks or regulatory penalties. But when an organisation operates in multiple jurisdictions, there’s no one-size-fits-all solution. The DPO must balance local compliance demands with overarching corporate risks, reflecting a strategic function that harmonises global and regional needs.

Building a Cohesive Privacy Framework

At the heart of managing data protection across various subsidiaries lies the need for a cohesive and flexible privacy framework. A unified data protection strategy provides a structure for decision-making, resource allocation, and policy implementation. The framework should be flexible enough to accommodate local legal requirements, such as the General Data Protection Regulation (GDPR) in Europe, the Personal Information Protection Law (PIPL) in China, or the Brasilian General Data Protection Law (LGPD), while being sufficiently robust to promote consistent organisational principles.

This begins with defining a core set of privacy standards built around key global norms. These might reflect the GDPR’s principles of transparency, accountability, and purpose limitation, which have become de facto global standards. These organisational principles should be codified into global policies and guidelines. However, recognising that interpretations and legal obligations vary between jurisdictions, local subsidiaries should be empowered to adapt these standards through local policies that are consistent with—but not in contradiction to—global policies.

Strong internal governance bodies, such as a central privacy office or cross-functional data protection committees, can support subsidiaries in implementing these frameworks. Regular reporting and collaboration encourage alignment and visibility across the organisation.

Centralised Oversight with Local Autonomy

While centralised oversight helps maintain consistency, autonomy at the subsidiary level is vital. Local business units typically have the best understanding of operational realities, customer expectations, and their jurisdiction’s regulatory environment. Respecting the autonomy of local DPOs or privacy leads facilitates more effective, practical compliance.

The global DPO—or Chief Privacy Officer (CPO) in some organisations—should play a governance and coordination role, defining global objectives, setting a clear tone from the top, and acting as a point of escalation. Subsidiary DPOs act as intermediaries, translating corporate guidelines into local actions. Delegation of responsibilities must be formalised through data protection operating models, decision rights matrices, and documented role descriptions.

Furthermore, each local privacy officer must be equipped with adequate training and support. Building a network of regional DPOs or privacy champions helps promote shared learnings and best practices. These networks can function like a virtual community of practice and serve as an early warning system for emerging challenges or legal updates.

Regulatory Engagement and Jurisdictional Sensitivity

Engaging with regulators is a delicate task even for organisations operating in a single country. For multinationals, it becomes more complex, involving diverse data protection authorities (DPAs) with different expectations and enforcement styles. In countries with strong regulatory regimes, such as Germany or South Korea, the local DPO must maintain an open yet cautious relationship with the DPA. Elsewhere, where enforcement may be less stringent, the organisation must still maintain high standards, recognising that regulatory oversight can change quickly.

Transparency in dealing with regulators—whether in the form of cooperation during audits or timely breach notifications—is essential. It is advisable for each subsidiary to establish clear procedures for engaging with local authorities, while ensuring alignment with the global strategy. The corporate DPO should be notified about all significant regulatory engagements, particularly those that may create legal precedent or reputational risk.

Jurisdictional sensitivity extends beyond regulatory engagement. In some countries, the concept of privacy is viewed through a different lens or influenced by national laws that seem contradictory to privacy rights—as seen in requirements for data localisation, government oversight, or freedom of expression debates. The global DPO must be culturally aware, carefully navigating these contexts without undermining corporate values or legal obligations.

Data Mapping and Cross-Border Data Transfers

A core operational requirement in managing multinational data protection is achieving visibility into the data ecosystem. Without understanding what data is processed, where it resides, how it flows across borders, and who has access to it, there can be no effective privacy management. Data mapping at both the enterprise and subsidiary levels is essential to documenting processing activities, fulfilling Article 30 Records of Processing under the GDPR, and managing risk assessments.

However, data mapping is not a one-off exercise. It requires continuous updates, collaboration between business functions, and appropriate tooling to automate discovery and classification. Subsidiaries should maintain records tailored to their processing activities, and these should feed into central repositories to give the global DPO an organisation-wide view.

Cross-border data transfers continue to be one of the most technically and legally complex issues. Subsidiaries often need to share personal data with headquarters or other regional hubs. In the EU context, transfers to third countries—especially those without adequacy decisions—require mechanisms such as standard contractual clauses (SCCs), binding corporate rules (BCRs), or other safeguards specified by law.

Managing these transfers centrally improves consistency, but execution typically falls to local teams. Policies should dictate acceptable transfer mechanisms, data transfer impact assessments must be conducted, and mitigation strategies put in place. Regulatory guidance and case law, such as the Schrems II judgment, illustrate the importance of thorough, documented justifications and supplementary measures.

Driving a Culture of Privacy Across Borders

Legal compliance is only one aspect of effective privacy management. Driving a culture of privacy is what transforms privacy from a reactive compliance function into a source of competitive advantage and public trust. Achieving this in a multinational environment is an exercise in leadership, communication, and cultural intelligence.

This starts with awareness. Training programmes must be tailored to local contexts, languages, and industry sectors. Generic courses should be complemented by scenario-based training specific to local activities—such as direct marketing, CCTV usage, or customer service.

Leadership commitment is key. Senior executives at both global and subsidiary levels should be vocal advocates of privacy. Embedding privacy metrics into performance goals—especially for functions like marketing, HR, and IT—helps reinforce these values. Aligning privacy with corporate social responsibility or ESG objectives may also help gain support in cultures where regulatory compliance alone isn’t a compelling motivator.

Engagement platforms such as data ethics councils, internal dashboards, or employee feedback loops can foster a participatory culture. The global DPO should ensure that privacy is framed as more than an obligation—it is a right, a value, and a strategic advantage.

Responding to Incidents and Building Resilience

Resilience is measured not by the absence of incidents but by how effectively they are managed. A centralised incident response framework—coordinated by the corporate DPO, but operationalised by local teams—ensures swift containment, legal assessment, and communication.

Every subsidiary must have a documented incident management plan, tailored to local legal and operational environments. Response teams should include representatives from legal, IT, communications, and the business units. Clear escalation paths, playbooks for common scenarios, and periodic simulations are indispensable preparation tools.

It is also vital to track minor incidents and near misses for learning purposes. These insights can help mature the incident response function over time. Lessons learned from breaches in one country may prevent similar events elsewhere, provided information flows freely.

Measuring Success and Demonstrating Accountability

Demonstrating accountability is a cornerstone of modern data privacy laws and is particularly important in an international setting. Multinational organisations must be able to show that they have not only implemented policies but that these policies are effective in practice across the globe.

Privacy key performance indicators (KPIs) should be designed to track programme maturity not just at a corporate level, but within each subsidiary. Common metrics include the number of data protection impact assessments (DPIAs) conducted, training completion rates, incident response times, or third-party risk ratings.

Mature privacy functions go further, using dashboards, audit trails, maturity assessments, and third-party reviews to benchmark performance. A formalised privacy assurance programme, integrated with internal audit or compliance functions, provides an independent view into both global and local implementation.

Conclusion

The successful management of data protection functions in a multinational context demands more than regulatory knowledge. It requires strategic vision, cultural competence, operational agility, and an unwavering commitment to ethical practice. The global DPO, together with local privacy leaders, must navigate disparate legal systems, complex organisational structures, and an evolving threat landscape—all while preserving the trust of data subjects and stakeholders.

True success lies not just in avoiding fines or meeting minimum requirements but in building a sustainable privacy-first culture that enhances business resilience, customer trust, and long-term value.