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- This represents a new step for AI system compliance. Although it doesn’t explicitly mention the DPO, the latter possesses the essential skills to contribute to this regulation. The cross-cutting nature of the DPO’s role, encompassing both legal and technical expertise, is a major asset, particularly regarding documentation, transparency, and the protection of fundamental rights—all requirements shared with the GDPR.
- The DPO’s Strategic Positioning in the Age of Artificial Intelligence
The launch of the 2025 survey puts the impact of artificial intelligence (AI) on the role of the Data Protection Officer (DPO) in the spotlight, highlighting the evolution of this profession in the face of technological advancements and new regulatory requirements. Implemented by the Ministry of Labour and Solidarity, the CNIL (French Data Protection Authority), and the AFCDP (French Association of Data Protection Officers), this survey seeks to understand how DPOs are adapting to new professional practices involving AI, while respecting the General Data Protection Regulation (GDPR) and the challenges posed by the AI Regulation (RIA). The survey explores training needs, working tools, and the DPO’s place within AI governance structures, in order to better anticipate the challenges related to the protection of personal data in increasingly intelligent systems. Artificial intelligence (AI) is profoundly transforming various sectors, and with it, the role of the Data Protection Officer (DPO). To explore these transformations, a new survey focusing on the challenges faced by Data Protection Officers (DPOs) in the context of AI has been launched. This article addresses initial reflections on the evolution of this profession, current governance issues, and the skills required to reconcile the GDPR and the Regulation on Artificial Intelligence (RIA). Context and launch of the 2025 survey The Ministry of Labour and Solidarity, the CNIL (French Data Protection Authority), and the French Association of Data Protection Officers (AFCDP) commissioned Afpa to conduct a comprehensive survey on the impact of AI on the role of the Data Protection Officer (DPO). Since 2018, the Directorate General for Employment and Vocational Training (DGEFP), in partnership with the CNIL, has been assessing the challenges related to the GDPR and the evolving role of the DPO. The 2025 survey was launched to focus on the new dynamics created by AI and the gradual implementation of the European AI Regulation (RIA). AI Governance Challenges for DPOs AI governance models within organizations raise new questions about the role of the DPO. With constantly evolving regulations, DPOs must navigate this complex environment while ensuring that the AI systems used comply with data protection standards. While the GDPR already requires DPO involvement in personal data processing, it is crucial to define how these requirements fit within the RIA framework. Skills needed to meet technological and regulatory challenges The increasing complexity of AI systems calls for an expansion of DPO skills. Traditional skills such as conducting impact assessments, mapping processing activities, and raising awareness among teams must now be combined with a thorough understanding of AI technologies and their ethical implications. Organizations will need to invest in appropriate training to enable DPOs to fully master these new challenges. The implications of the Artificial Intelligence Regulation
The RIA
This represents a new step for AI system compliance. Although it doesn’t explicitly mention the DPO, the latter possesses the essential skills to contribute to this regulation. The cross-cutting nature of the DPO’s role, encompassing both legal and technical expertise, is a major asset, particularly regarding documentation, transparency, and the protection of fundamental rights—all requirements shared with the GDPR.
The DPO’s Strategic Positioning in the Age of Artificial Intelligence
As the entry into force of the AI regulation redefines compliance roles, the role of the DPO must be reassessed. Beyond regulatory compliance, it is also about ensuring that digital ethics are respected and integrated at all stages of processes involving AI. New roles are emerging, such as AI compliance officer or digital ethics officer, challenging the traditional positioning of the DPO.
It is in this context that the 2025 survey aims to gather the vision of DPOs, in order to inform institutional actors and companies about the best practices to adopt to stay at the forefront of compliance and react effectively to new regulatory and technological requirements.
To read Midjourney V8 Alpha : Révolutionner la création visuelle grâce à l’IA
