# Does a mental health organisation need a Data Protection Officer?

URL: https://tymirahealth.com/resources/faqs/does-a-mental-health-organisation-need-a-data-protection-officer
For: Executives | Data protection and privacy | Reviewed by Independent clinical reviewer, Registered mental health clinician, Kenya | Last reviewed 8 November 2026

**Answer:** The ODPC's 2026 guidance for Data Protection Officers explains when one should be designated. It points to large-scale processing of sensitive data, such as health records, as a strong indicator. Its examples include a hospital designating a DPO, and smaller organisations using an external consultant on retainer, provided a named individual is the DPO. A DPO advises on compliance, impact assessments and breach response. Check the Act and guidance, or ask a data protection lawyer, about your organisation's size and activities.

Sources: Office of the Data Protection Commissioner: https://www.odpc.go.ke/wp-content/uploads/2026/07/ODPC-%E2%80%93-Guidance-Note-for-Data-Protection-Officers-DPOs.pdf - Kenya Law: https://new.kenyalaw.org/akn/ke/act/2019/24/eng@2022-12-31

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