The highly regulated financial market, the regulation and practice of the supervisory authority tend to change particularly quickly. What data protection matters most commonly require external support? Usually, external legal support is advisable for reviewing privacy policies, for international data transfer or for designing internal processes (e.g. access requests, data breach notification, privacy impact assessments, etc.). Particularly important is external advice when conducting substantial internal project, such a migration to a new cloud (particularly if this cloud is hosted outside Switzerland). Generally, an external counsel can offer a DPO insight on how other, similar companies resolve similar issues regarding data protection, which can be very beneficial for the DPO. Given that the revised FADP brings many new requirements and new processes, it is advisable that a DPO tasked with designing a data protection framework engage an external counsel in order to get the necessary know-how. Do you expect new technology and the growth of digital assets to increase the need for DPOs to seek support? New technologies such as ‘distributed ledgers’, the ‘internet of things’ and artificial intelligence can of course have an impact on data protection provided personal data is processed. It can be very challenging and time-consuming to design such products and services compliantly. This is where an external counsel can provide valuable support providing their know-how to the DPO. EXPERT INSIGHT 65 About Dr Lukas Lezzi Dr Lukas Lezzi is a qualified lawyer in Switzerland and holder of the IAPP certifications CIPP/E and CIPM. He studied law in Zurich and received his doctorate in financial market law, and has worked as the data protection officer for a major Swiss financial infrastructure provider and a major Swiss law firm before founding his own boutique firm. He advises national and international client in data protection and Swiss regulatory matters. Currently, he and his team are advising several companies in the implementation of the new FADP. Contact Lukas Lezzi Founder, LezziLegal Etzelstrasse 3, Postfach, 8038 Zürich, Switzerland Tel: +41 79 315 10 10 E: lezzi@lezzilegal.ch www.lezzilegal.ch It is advisable that a DPO tasked with designing a data protection framework engage an external counsel in order to get the necessary know-how.
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