Part 4: Whats's The Difference Between DPO and CDO?

June 17, 2025 | Written by Freddy Loo

The DPO's primary job is to protect the data, while the CDO's primary job is to capitalise on the data's value.

The Data Protection Officer (DPO)

Main Objective: Compliance and Risk Mitigation. The DPO is focused on ensuring the organization processes personal data in a way that is ethical and compliant with laws like Malaysia's Personal Data Protection Act (PDPA). Their goal is to protect the rights of individuals (customers, employees) and protect the organization from legal penalties and reputational damage.

Core Focus: "How should we protect data?" They are concerned with the principles of data processing—lawfulness, fairness, transparency, data minimisation, and security.

Key Responsibilities:
- Monitoring compliance with data protection laws.
- Advising on Data Protection Impact Assessments (DPIAs).
- Acting as the main contact for regulatory authorities (like the Personal Data Protection Commissioner) and for individuals inquiring about their data rights.
- Fostering a culture of data privacy within the organisation.

Legal Mandate: In many jurisdictions, the DPO is a legally mandated role.

A defender and a steward, viewing data through the lens of risk, privacy, and individual rights.

versus....

The Chief Data Officer (CDO)

Main Objective: Strategy and Value Creation. The CDO is a strategic business leader focused on managing and utilising the entire organization's data as a corporate asset. Their goal is to drive business growth, improve efficiency, and create competitive advantages through data.

Core Focus: "How can we use data?" They are concerned with data quality, governance, accessibility, analytics, and monetisation.

Key Responsibilities:
- Developing and executing the enterprise data strategy.
- Overseeing data governance frameworks and improving data quality.
- Leading analytics and business intelligence initiatives to extract insights.
- Promoting a data-driven culture to improve decision-making across all departments.

Legal Mandate: The CDO is a strategic business appointment, not a legally required one. Organisations use this to gain a competitive edge.

Perspective: An innovator and an architect, viewing data as a valuable asset to be leveraged for business advantage.

Conflict of Interest
It's crucial to note that in most cases, the same person cannot be both the DPO and the CDO. The CDO's goal to maximize data usage could directly conflict with the DPO's duty to minimise data collection and ensure strict protection. The DPO must be able to independently challenge and audit the activities driven by the CDO.

What's the critique of such a demarcation of roles?