关键词: 企业数据治理, 数据合规官, 管理过失, 责任激励, 责任边界

Abstract: Data compliance officers play a central role in enterprise data governance, and many countries have explored relative legislations and practice. Through literature analysis and comparative analysis, this paper reflects on the current compliance dilemma in enterprise data governance, and proposes that data compliance officers are strategic senior managers with independent status, whose personnel selection must meet professional qualification standards. Their functions cover six aspects, including data cognition, data consulting and data processing and so on. In terms of enterprise data governance responsibilities, it is necessary to clarify the personal legal responsibility boundary of data compliance officers. Therefore, this paper clarifys the governance boundaries of data compliance officers in China with reference to the international experience such as the special attention standard, the specific intention (tacit consent) standard and the two intermediate responsibility standards. In order to realize the effective construction of enterprise data compliance governance, the enterprise data governance system centered on data compliance officers should cover the core content of data compliance officers in at least four aspects: data risk management, data compliance communication, data processing supervision and responsibility incentives.

Key words: Enterprise data governance, Data compliance officer, Management negligence, Responsibility incentives, Responsibility boundaries