For organisations in Malaysia who fall under the mandatory Data Protection Officer (DPO) appointment thresholds, a follow-up question might be:
“Who is the right person for the job, and what is legally expected of them?”
A DPO is a role that requires the right mix of eligibility, expertise, and independence to meet the expectations of the Personal Data Protection Commissioner, and in this article, we break down official DPO requirements, including:
- basic qualifications
- core competencies, and
- training recommendations
By the end, you’ll be able to confidently assess if your DPO candidate is up to the task.
Note: For those unfamiliar with the DPO appointment thresholds, start with our guide to which organisations in Malaysia need to appoint a Data Protection Officer (DPO).
Who can be appointed as DPO?
The Appointment of DPO Guideline requires a DPO meet the following minimum requirements:
- be physically present in Malaysia for at least 180 days/per year
- be easily contactable via any means
- be fluent in Bahasa Malaysia and English
- be familiar with the data protection laws, your organisation’s business operations and information technology and data security
- have personal qualities such as in integrity, high professional ethics and understanding of corporate governance, and
- have the ability to promote data protection culture within the organisation
DPO Competency Guideline KSA model
The DPO Competency Guideline’s KSA model outlines core capabilities a DPO must demonstrate:
| Component | Meaning | Illustration |
| Knowledge | What a DPO must understand and be familiar with | Understanding of the PDPA, data subject rights, DPIAs, breach protocols, data security etc. |
| Skills | What a DPO must be able to do, acquired through training or experience | Drafting PDPA-compliant policies, conducting internal training, managing breach responses, performing DPIAs etc. |
| Abilities | The capability to apply knowledge and skills in practical settings | Translating legal and compliance obligations into practical procedures for your business, and recommending steps to mitigate personal data processing risks etc. |
6 core DPO job functions
A competent DPO should be capable of handling six core functional areas (as defined in the DPO Competency Guideline):
- Advisory & Support – Provide guidance and advice on PDPA matters.
- Risk Management & Assessment – Identify, assess, and mitigate risks related to the processing of personal data.
- Compliance Oversight & Monitoring – Oversee adherence to personal data protection laws and policies within the organisation.
- Audit & Reporting – Prepare compliance reports, conduct or facilitate regular personal data audits, and record-keeping.
- Communications & Stakeholder Engagement – Promote personal data protection practices through staff training and awareness initiatives, and coordinate with internal and external stakeholders.
- Regulatory & Data Subject Management – Liaise with and handling PDPC queries, handle data subjects’ request and complaints, and breach notifications.
“DPO Competency” as defined by PDP
The DPO Competency Guideline sets out a two-tier framework to define the level of capability expected from a DPO.
| Fundamental | This is the minimum level of core competencies required of all DPOs. It covers the six competency areas (advisory, risk, monitoring, etc.) and ensures the DPO can fulfil their responsibilities under the PDPA. DPO may meet this through: 1. Their own professional expertise; 2. Support from an internal team; and/or 3. Assistance from external experts (e.g. legal advisors or cybersecurity consultants). Every DPO is expected to meet this regardless of company size or sector. |
| Advanced | This tier applies to organisations with more complex, high-risk, or large-scale personal data activities. DPO at this level should be able to: 1. Demonstrate all Fundamental Tier competencies (with a high degree of independence and expertise) 2. Lead strategic and organisation-wide initiatives; 3. Manage cross-border data protection issues; 4. Translate PDPA into enterprise-level governance and operational procedures. The need for Advanced Tier competency should be assessed based on the size, sensitivity, and risk exposure of your business, it is not mandatory for all. |
Does a DPO need training or certification?
While there is no mandatory certification (yet), the Commissioner strongly encourages DPO to undergo recognised training to ensure they can perform their duties effectively.
The DPO Professional Development Pathway & Training Roadmap has two training pathways:
- Fundamental Tier – structured around six core competencies outlined in the DPO Competency Guideline.
- Advanced Tier – structured around the responsibilities outlined in the DPO Competency Guideline.
There are also two ways training can be recognised:
- Short-term Recognition: Certificates of Completion (Fundamental / Advanced).
- Long-term Recognition: Professional Certification as a Certified DPO (Fundamental / Advanced).
To ensure quality and proper training, organisations should obtain training from recognised training provider. The Commissioner has outlined requirements under the Management of DPO Training Service Providers Guideline, which accredits training organisations offering PDPA-aligned DPO courses.
Choosing the right DPO matters
The role of a DPO is a strategic compliance function that demands legal awareness, risk management expertise, and strong communication skills.
As outlined above, the DPO needs to fulfil the KSA model and perform across the six core competency areas. If your organisation processes more complex or sensitive personal data, a higher level of competency will be required to manage the increased risks effectively.
When assessing a potential DPO, use the official guidelines to evaluate both eligibility and competency, and don’t compromise on capability.
Book a free DPO readiness consultation
Whether you are planning to appoint someone internally or explore an outsourced solution, our team can guide you through the requirements and help you make a confident and compliant decision.
Book a free DPO readiness consultation with us today and take the first step toward PDPA compliance.
