Q: I am a data controller operating in the recruitment sector. Will I need to appoint a Data Protection Officer?
A: Not every data controller will necessarily need to appoint (or hire) a Data Protection Officer (DPO).
However, this is a matter which will need to be assessed on a case-by-case basis.
It might be worthwhile to seek legal advice to inform your decision on this subject.
A Data Protection Officer may be needed to complete Data Protection Impact Assessments, or to oversee certain processes. Specifically: when an organisation processes large volumes of personal data; when processing may pose particular risk to individuals; or, when special categories of sensitive personal data are being processed.
It is realistic to see how each of these situations could quite easily arise within the recruitment sector.
A group of organisations may choose to appoint a single DPO to oversee processing across an entire data chain.