Amendment 349· Digital Omnibus proposal Recital 36b (new)

(36b)Micro, small and medium-sized enterprises and small mid-caps which are not related undertakings should be able to designate a single data protection officer jointly, provided that the officer is easily accessible from each establishment and that the conditions of independence and absence of conflict of interest laid down in Articles 38 and 39 are met in respect of each controller concerned. Such pooling reduces compliance costs without lowering the level of protection, and should not result in the officer being placed in a position of dependence in relation to any of the controllers concerned.