in such cases, it is the responsibility of the management of the BUs in these countries to ensure that the unit complies with local requirements related to the potential appointment of a DPO. The Group Privacy Officer shall be consulted prior to the appointment of a local DPO, and any locally appointed Data Protection Officer must be endorsed by the Group Privacy Officer. 2.7 ECCO’s Data Protection Compliance Programme In order to ensure compliance with this Policy and with the general personal data legislation and that ECCO is able to demonstrate compliance herewith, the Group Privacy Officer shall be responsible for the development, implementation, and maintenance of a personal data compliance programme within ECCO. This shall include, but is not limited to - Appropriate privacy policies, procedures, and other compliance tools - Appropriate training activities for ECCO’s employees to increase their awareness of and compliance with ECCO’s personal data compliance programme. - Appropriate compliance monitoring and auditing processes All ECCO employees are obliged to cooperate with the Group Privacy Officer and the locally appointed Data Protection Coordinators and Data Protection Officers regarding development, implementation, maintenance, and monitoring of ECCO’s Personal Data Compliance Programme. The compliance programme shall be based on the high standards of personal data regulations within the EU. Local legislation may, however, require a different protection and it is the responsibility of the local management of each BU to ensure that necessary local adaptations are implemented. Furthermore, it is the responsibility of the local management of each BU to ensure that mandatory registrations, authorisations, and notifications to local Data Protection Agencies are obtained and maintained. The Group Privacy Officer shall be informed of all local adaptations and registrations etc. and must be consulted prior to the implementation of locally required data protections to ensure that they are in accordance with ECCO’s Personal Data Compliance Programme. 57
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