Data governance is no longer limited to technique or legal compliance. Faced with regulatory stacking and the rise in strategic risks, a new role could impose itself within companies: that of Chief Data Compliance Officer.
Unpublished regulatory convergence
The GDPR was a turning point. But it was only the beginning. For the past five years, European texts that have framed digital uses have multiplied at a sustained pace. Next to the GDPR, which supervises the protection of personal data, several sectoral or transversal regulations have appeared:
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- NIS2 (Network and Information Security Directive) : impose reinforced cybersecurity standards in so -called “essential” sectors, including energy, transport, health, and certain digital services.
- Dora (Digital Operational Resilience Act) : aims at the financial sector, with precise requirements on IT resilience, penetration tests and supplier risk management.
- Cra (Cyber Resilience Act) : impose safety obligations from the design of digital products (hardware and software).
- RIA (Artificial Intelligence Regulation) : Frame the uses of AI according to an approach based on the level of risk.
- Data Act,, Eprivacy,, European Health Data Spaceetc. : other texts are in preparation or in the transposition phase.
It is no longer a framework. It is a system. And this system now affects all the functions of the company: legal, CIO, purchases, products, innovation, marketing, HR, etc.
Fragmented management, sometimes dangerous
Faced with this complexity, the majority of companies still operate with a scheme of fragmented actors:
| Function | Perimeter |
|---|---|
| Dpo | Personal data and GDPR |
| RSSI/CISO | Technical cybersecurity |
| Legal/Compliance | Regulatory responses, contracts, audits |
| Chief Data Officer | Data valuation, quality, governance |
| Dsi | IT infrastructure and tools |
| Trades | Document daily use |
Each actor acts on its perimeter, but None has transversal vision or mandate to pilot the entire conformity of data from data.
Example: a company can comply with the GDPR but not in accordance with NIS2, or develop an AI system with high commercial potential without realizing that it could be considered “at high risk” within the meaning of the RIA.
Why create a Chief Data Compliance Officer?
The creation of a Chief Data Compliance Officer (CDCO) aims at Get out of silos managementby establishing a transverse function dedicated to the overall data control of data.
Its key missions:
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- Call up regulatory obligations Applicable to the company according to data types, processing, uses and risks.
- Supervise cross -conformity Projects (cloud, AI, cybersecurity, HR treatments, marketing, etc.).
- Coordinate existing functions : DPO, RSSI, Legal, DSI, CDO, Purchasing, Crafts.
- Establish a unified reporting For the control authorities (CNIL, ANSSI, ACPR, etc.).
- Anticipate the arrival of new texts and adapt internal practices.
- Pilot the reversibility and sovereignty of the datain connection with infrastructure choices (cloud, accommodation, storage).
This position becomes a strategic referentcapable of evaluating not only compliance, but also the business, reputation and regulatory impacts of data decisions.
A coherent framework to avoid regulatory debt
The Chief Data Compliance Officer allows you to create a Unified vision of conformitybreaking with the logic of regulatory reaction which still prevails in many organizations. It structures an approach proactive and prioritizedat the service of organizational resilience.
| Advantage | Impact on the company |
|---|---|
| Centralized vision | Death angles reduction |
| Simplified regulator dialogue | Save time and legal clarity |
| Anticipation of sanctions | Financial risk reduction |
| Unified governance | Better interfunctional efficiency |
| Prioritization of investments | Rational allocation of IT, security, legal budgets |
“This position is the DPO+ of tomorrow”
In some large companies, this function is starting to emerge under various titles: Chief Data Risk Officer,, Data Compliance LeadOr Data Governance & Risk Manager. Their common points: a transverse mandate, an often double attachment (legal / DG or DSI), and a mission ofInterface between data strategy and regulations.
This position also anticipates the evolution of the DPO, whose missions are widening more and more beyond the strict perimeter of the GDPR.
Towards a professionalization of data compliance
Far from being an administrative addition, the Chief Data Compliance Officer is a structural response to the evolution of the European regulatory framework. In an environment where data is both assets, risk, and responsibility, this role can become a strategic advantageespecially for companies operating in critical, regulated or sensitive environments.
It is no longer simply a question of “checking boxes”, but of piloting a compliance by designaligned with the digital and geopolitical ambitions of Europe.
