Does Plum have a Data Protection Officer for incidents?

Incident response is not purely an engineering exercise. When a security event touches personal data, the response must satisfy legal notification timelines, preserve data subject rights, and remain consistent with regulatory obligations. Xoxoday Plum addresses this by embedding a Data Protection Officer directly into its incident response workflow, treating privacy as a first-class concern alongside containment and remediation.

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The DPO’s Role During an Incident

The DPO reviews every incident that potentially involves personal or sensitive data to determine whether it constitutes a reportable breach. Under frameworks like GDPR, a notifiable breach must be reported to the relevant supervisory authority within 72 hours of discovery. Xoxoday Plum’s DPO holds responsibility for making that determination, preparing regulatory notifications, and coordinating data subject communication when required. The DPO also ensures that containment and recovery measures do not inadvertently conflict with data protection principles. Access restrictions, forensic data collection, and recovery procedures are each reviewed to confirm alignment with data minimization and purpose limitation requirements.

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Alignment with ISO 27001 and SOC 2 Type II

Xoxoday Plum maintains certifications under ISO 27001 and SOC 2 Type II, both of which require documented incident management procedures that account for privacy impact. The DPO’s participation ensures that incident response runbooks stay aligned with these standards and that the evidence trail generated during an investigation satisfies the audit requirements expected by external assessors. For enterprise customers whose employee data flows into Xoxoday Plum from HR platforms like Workday, SAP SuccessFactors, or Darwinbox, DPO oversight provides assurance that any incident affecting that data is handled with the same rigor applied to core HR records — not treated as peripheral to the response effort.

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Data Subject Rights During Active Incidents

A person affected by a data incident holds rights that do not pause while technical teams investigate. The right to be informed, the right to restrict processing, and the right to erasure all remain active during an ongoing incident. Xoxoday Plum’s DPO maintains responsibility for ensuring these rights are honored in parallel with technical remediation — not deferred until after the incident is closed. This means incident response at Xoxoday Plum operates as a coordinated effort across security, legal, and privacy workstreams, each with defined ownership. A breach is not declared resolved until the DPO confirms that all regulatory obligations have been met and that data subject rights have been fully addressed.

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Practical Impact for Enterprise Buyers

For procurement teams and IT security reviewers evaluating Xoxoday Plum, the presence of a DPO in the incident response chain provides a concrete audit artifact. When an incident occurs, there is a named, accountable role responsible for privacy outcomes — not a shared responsibility across engineering teams. This structure directly supports the vendor due diligence requirements found in enterprise procurement frameworks and data processing agreements. Learn more: Xoxoday Plum Help Centre — Process, Strategy & Methodology