Is a public limited company port required to appoint a Data Protection Officer (DPO)?
A public limited company port is not directly obliged to appoint a DPO, as a public limited company port is not considered a public authority or public body within the meaning of the GDPR.
You can also look at which private companies are obliged to have a DPO, and here it is a condition that the company's core activity must consist of processing personal data.
However, the issue is not completely clarified, and there has been no recent new practice from the Danish Data Protection Agency. Even though a public limited company port is not obliged to have a DPO, the port can still have one.
The above answer is from a personal data law perspective based on the General Data Protection Regulation. There may be other cases where an A/S port will be considered a "public body" or "public undertaking". It will depend on the specific legal area and legislation.
The above is a concrete opinion and if concrete decisions are to be made, it will need to be investigated further.
