Role Comparison

DPO vs CISO — What's the difference?

Q: Who handles a security incident?

Both, in coordination. CISO handles technical investigation — what happened, where, ongoing, blocking. DPO handles regulatory — required notification, drafting, customer communication, PR management. Two non-interchangeable parts.

Both roles sound similar. Both are "information officers". But in practice they are from different worlds: the DPO (Data Protection Officer) deals with data subject rights and privacy law; the CISO (Chief Information Security Officer) deals with protecting information assets against cyber threats. Practical guide with comparison, RACI, and a solution for: can both roles be the same person?

Comparison

Nine dimensions of difference

Dimension	DPO	CISO
Primary role	Protect rights of data subjects and their privacy	Protect organizational information assets
Legal basis	Amendment 13 to Privacy Protection Law	2017 Security Regulations, ISO 27001, banking management
Reporting	Direct to management, independent	Reports to CTO / CEO / Audit Committee
Expertise	Privacy law + data processing + regulation	Cyber + security + infrastructure
Daily task example	Reviews new DPA, responds to access request	Analyzes intrusion alert, runs penetration test
Monthly task example	Performs DPIA for new project	Cyber risk review, patching oversight
External contact	Privacy Protection Authority	CERT-IL, Bank of Israel (banks), security vendors
Independence requirement	Built-in — cannot be decision-maker on processing	Required but less strict
Mid-size org model	Outsourced (DPO as a Service)	Internal or outsourced (CISOaaS)

RACI

Responsibility matrix (RACI)

Who is accountable for what? In a mid-size organization with separate DPO and CISO, here are 12 typical tasks and responsibility split. R = Responsible (executes), A = Accountable (ultimate owner), C = Consulted (advises), I = Informed (kept aware).

Task	DPO	CISO	Other
DPO appointment and Authority registration	R	-	CEO: A
Personal data asset mapping	R/A	C	IT: C
Information security program	C	R/A	IT: R
SaaS vendor agreements (DPA)	R/A	C	Legal: C
Security incident — Authority notification	R/A	C	CEO: A
Security incident — technical investigation	C	R/A	Forensics: R
Employee training — privacy	R/A	C	HR: C
Employee training — cyber security	C	R/A	HR: C
DPIA for new project	R/A	C	PM: C
Penetration testing	I	R/A	External vendor: R
Response to data-subject request (access/correction)	R/A	I	IT: C
ISO 27001 work plan	C	R/A	Auditor: R

Conflict of interest

The conflict question — is it allowed?

Is CISO who is also DPO a forbidden conflict?

Opinions differ. The Israeli Privacy Authority issued a 2025 opinion that combining the roles is allowed only in small organizations or where no conflict of interest exists. In mid-size organizations and above, the CISO makes security decisions the DPO must oversee — a built-in conflict of interest.

CEO / General Counsel / CIO as DPO

The Authority opinion explicitly disqualified such combinations in most organizations. CEO makes all the decisions the DPO must oversee. CIO is responsible for the systems the DPO audits. GC sometimes represents positions the DPO must challenge.

In a small organization — what does work

A small organization with 5-20 employees and no sensitive data at scale — usually not required to have a DPO at all. If required — options: (a) combined CISO+DPO only if the role-holder is not an operational decision-maker; (b) DPO as a Service external; (c) business partner independent of data-processing decisions.

The "external DPO, internal CISO" model

Most common model in mid-size organizations. Internal CISO handling cyber and infosec. External DPO (outsourced) handling privacy and law. GRC + Privacy package offers both roles from one provider.

Frequent questions — DPO and CISO

Can a CISO be a DPO?

Theoretically — yes, in a small organization without conflict of interest. Practically — not recommended in most organizations. The Authority disqualified the combination in conflict-of-interest situations, and in mid-size organizations that is usually the case. Recommendation: two different people, or combined CISO + DPO as a Service when they are professionally coordinated but not the same person.

What is the cost difference between the two roles?

Senior internal CISO — 45,000-70,000 ILS/month salary. Part-time CISOaaS — 8,000-25,000 ILS/month. Senior internal DPO — 40,000-60,000 ILS/month salary. DPO as a Service — 5,000-28,000 ILS/month. In mid-size organization, both senior internal roles = 90,000-130,000 ILS/month. Both outsourced = 13,000-50,000 ILS/month.

Who handles a security incident?

Both, in coordination. CISO handles technical investigation — what happened, where, ongoing, blocking. DPO handles regulatory — required notification, drafting, customer communication, PR management. Two non-interchangeable parts.

Is there a profession combining both?

"GRC Specialist" / "Privacy and Security Consultant" — roles that have become popular in SaaS companies. In practice they perform both functions, but in an organization with clear accountability and a regulatory framework — two separate roles are required.

What about ISO 27001 and ISO 27701?

ISO 27001 is the CISO standard (information security). ISO 27701 is the privacy extension of ISO 27001 (PIMS). Both require two complementary documentation systems. CISO typically leads 27001, DPO leads 27701.

Do you have a CISO too?

We are DPOs. The CISO in our bench is a separate professional with deep cyber background. When combined service is needed — GRC + Privacy package offers both roles. We don’t offer CISO alone — when a client wants just CISO, we recommend trusted partners.

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