Clear role delineation for an effective data protection organisation

Data Protection Coordinator Training - Roles & Responsibilities: Coordinator vs DPO

Understand the different roles and responsibilities of data protection coordinators and Data Protection Officers.

  • 01Clear delineation of roles and responsibilities
  • 02Optimised collaboration between the coordinator and the DPO
  • 03Efficient data protection organisation and processes
  • 04Legally sound task allocation and communication
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Data Protection Coordinator vs DPO - Roles & Responsibilities

Successfully implementing a GDPR-compliant data protection organisation requires a clear delineation between the roles of the data protection coordinator and the Data Protection Officer (DPO). This training imparts sound knowledge of the different tasks, competencies, and responsibilities of both positions, as well as their optimal collaboration.

Our training provides a systematic examination of the different roles of data protection coordinators and Data Protection Officers and conveys practical solutions for successful collaboration.

2 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

Role Delineation and Legal Foundations

Systematic examination of the different legal requirements and responsibilities of data protection coordinators and DPOs.

  • GDPR requirements for both roles in detail
  • National particularities and interpretations
  • Liability and responsibility aspects
  • Supervisory authority expectations and practice
02

Practical Collaboration and Organisational Models

Development of effective cooperation structures and implementation of optimal organisational models for both roles.

  • Task and competency allocation in practice
  • Communication channels and reporting obligations
  • Conflict prevention and escalation management
  • Integration into existing organisational structures

5 phases

Our Training Approach

We impart sound knowledge of role delineation and effective collaboration through a structured combination of legal analysis and practical implementation.

  1. Systematic analysis of legal foundations and requirements

  2. Development of clear role and responsibility matrices

  3. Practice-oriented simulation of cooperation scenarios

  4. Development of individual organisational models

  5. Implementation support and performance controlling

Sarah Richter

Your contact

Sarah Richter

Head of Information Security, Cyber Security

10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security

+49 69 913 113-01 info@advisori.de LinkedIn
A clear division of roles between the data protection coordinator and the DPO is the key to an efficient data protection organisation. Our training creates the necessary clarity for successful collaboration between both functions.

Our Strengths

  • 01Many years of experience in establishing successful data protection organisations
  • 02Proven models for role and task allocation
  • 03Sound legal expertise and organisational know-how
  • 04Individually tailored solutions for different organisational structures

Expert Tip

A clear division of roles between the data protection coordinator and the DPO is essential for an efficient data protection organisation and prevents disputes over competencies as well as compliance gaps.

18 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about Training - Roles & Responsibilities: Coordinator vs DPO

What legal differences and liability aspects exist between the data protection coordinator and the DPO, and how can organisations structure these optimally?

The legal differences between the data protection coordinator and the DPO are fundamental to designing a compliance-conformant and liability-secure data protection organisation. While the DPO must fulfil specific statutory requirements, the role of the data protection coordinator is more flexibly structured, but no less important.

⚖ ️ Legal foundations and differences:

• DPO requirements under GDPR Art. 37–39: Mandatory designation for certain data processing activities, specific qualification requirements, independence requirement, and a direct reporting line to senior management.
• Coordinator flexibility: No specific statutory requirements, but a de facto necessity for operational data protection implementation in larger organisations.
• Liability distribution: The DPO is liable for proper advisory and oversight functions; the coordinator is liable for operational implementation within their area of responsibility.
• Freedom from instruction vs. integration: The DPO must be able to act free from instructions; the coordinator is embedded in normal hierarchical structures.

🔧 Structural optimisation approaches for organisations:

• Clear delineation of competencies: Definition of precise task catalogues and decision-making authorities to avoid gaps or overlaps in responsibility.
• Escalation mechanisms: Development of structured communication and escalation channels between both roles and to senior management.
• Documentation obligations: Establishment of specific documentation requirements for both roles to support evidence management and liability delineation.
• Resource allocation: Adequate provision of both functions with the necessary resources, tools, and authorities for effective task fulfilment.

How can data protection coordinators and DPOs collaborate effectively in practice without disputes over competencies, and what success models exist?

Successful collaboration between the data protection coordinator and the DPO requires well-considered cooperation structures that take into account both the legal requirements and the practical needs of the organisation. Successful models are based on clear communication, defined interfaces, and mutual understanding of the respective roles.

🤝 Success principles for effective collaboration:

• Complementary specialisation: Leveraging different strengths — the DPO for strategic advisory and oversight, the coordinator for operational implementation and process management.
• Regular alignment: Establishing structured communication routines with defined agenda items and decision-making responsibilities.
• Shared objectives: Development of common KPIs and success metrics that align both roles with overarching data protection goals.
• Conflict-preventive processes: Proactive clarification of borderline cases and development of decision matrices for typical situations.

💡 Proven success models in practice:

• Matrix organisation: DPO as strategic advisor with functional authority, coordinator as operational implementer with disciplinary integration into the line organisation.
• Team-based approach: Formation of a data protection team with clearly defined, complementary roles and shared responsibility for data protection outcomes.
• Project cooperation: Structured collaboration in specific data protection projects with role-based task allocation and joint success measurement.
• Escalation partnership: Development of a trusted working relationship with clear escalation channels for complex or cross-cutting data protection issues.

Which organisational structures and tools most effectively support optimal task allocation between the data protection coordinator and the DPO?

Optimal task allocation between the data protection coordinator and the DPO requires well-considered organisational structures and specialised tools that support both roles in their specific functions while enabling smooth collaboration. Modern data protection organisations rely on integrated solution approaches.

🏗 ️ Organisational structural elements for optimal task allocation:

• RACI matrix for data protection processes: Systematic assignment of responsibilities (Responsible, Accountable, Consulted, Informed) for all data protection-relevant activities.
• Governance structure: Establishment of data protection committees with defined roles for both functions and clear decision-making competencies.
• Reporting and monitoring: Development of specific reporting lines and KPI dashboards that provide both roles with relevant information for their task fulfilment.
• Escalation and communication matrix: Structured processes for information exchange, conflict resolution, and strategic decision-making.

🛠 ️ Technological tools and platforms:

• Integrated GRC platforms: Comprehensive Governance, Risk & Compliance systems with role-specific dashboards and workflow functions for both positions.
• Data protection management software: Specialised tools for records of processing activities, DPIA management, and data subject rights with differentiated access rights.
• Collaboration platforms: Modern communication and project management tools that enable structured collaboration and documentation.
• Monitoring and analytics: Automated compliance monitoring systems with individualised reports for strategic and operational levels.

How do organisations optimally design communication and reporting channels between the data protection coordinator and the DPO, and what challenges need to be addressed?

Designing effective communication and reporting channels between the data protection coordinator and the DPO is critical for a functional data protection organisation. Legal requirements, operational efficiency, and organisational realities must be brought into alignment while proactively addressing typical challenges.

🔄 Structural communication design principles:

• Hierarchy clarity: The DPO reports directly to senior management; the coordinator reports through the normal line organisation, but with defined functional coordination channels to the DPO.
• Information flow optimisation: Bidirectional communication with clear responsibilities for different types of information and escalation levels.
• Regular synchronisation: Structured coordination rhythms for operational updates, strategic planning, and crisis management.
• Documented processes: Written documentation of all communication channels, responsibilities, and decision-making competencies to avoid misunderstandings.

⚡ Typical challenges and solution approaches:

• Information asymmetries: Different information access and needs require structured information distribution processes and shared data sources.
• Priority conflicts: Different timeframes and urgency assessments require clear escalation mechanisms and shared prioritisation criteria.
• Cultural integration: Bridging the gap between the strategic DPO perspective and the operational coordinator viewpoint through regular perspective shifts and joint projects.
• Technological support: Implementation of suitable collaboration tools and dashboards that provide both roles with relevant, up-to-date information.

What role does the DPO's independence play in collaboration with the data protection coordinator, and how is this ensured in practice?

The independence of the DPO is a fundamental principle of the GDPR that requires particular attention when collaborating with the data protection coordinator. This independence must not be compromised by overly close operational linkages, yet must still enable effective cooperation.

⚖ ️ Legal independence requirements:

• Freedom from instruction: The DPO must not receive instructions regarding their data protection tasks, including from the data protection coordinator or their superiors.
• Avoidance of conflicts of interest: Clear separation between the DPO's oversight function and the coordinator's operational implementation responsibility.
• Direct reporting line: The DPO reports directly to the highest management level, independent of the coordinator's organisational structures.
• Resource autonomy: The DPO must have sufficient resources to fulfil their tasks independently.

🛡 ️ Practical assurance measures:

• Structural separation: Organisational separation of both roles in different areas or reporting lines, with clear cooperation interfaces.
• Functional delineation: Precise definition of areas of responsibility to prevent interference in the DPO's core competencies while enabling collaboration.
• Transparent processes: Open communication about roles, boundaries, and cooperation possibilities to all parties involved and to the organisation.
• Regular review: Continuous assessment of independence preservation through internal audits and external advisory to ensure compliance-conformant structures.

How can organisations measurably increase the efficiency of their data protection organisation through optimal task allocation between the coordinator and the DPO?

Measurably increasing the efficiency of the data protection organisation through optimal task allocation requires systematic KPI development, structured process optimisation, and continuous performance monitoring. Successful organisations use data-driven approaches to assess and improve their data protection structures.

📊 Efficiency KPIs for the data protection organisation:

• Process speed: Throughput times for DPIA procedures, data subject request processing, and incident response cycles.
• Quality indicators: Error rates in data protection documentation, completeness of records of processing activities, and compliance scores in internal audits.
• Resource efficiency: Cost optimisation through clear role allocation, avoidance of duplicate work, and effective capacity utilisation.
• Stakeholder satisfaction: Assessment of collaboration by business units, senior management, and external partners.

🚀 Optimisation strategies for maximum efficiency:

• Collaboration maximisation: Utilising the complementary strengths of both roles through strategic task assignment and coordinated working methods.
• Automation potential: Identification and implementation of process automation that relieves both roles and increases efficiency.
• Continuous improvement: Establishment of regular review cycles to assess and adjust task allocation based on performance data.
• Best practice integration: Systematic collection and implementation of proven practices from successful data protection organisations for continuous efficiency improvement.

What critical success factors determine the successful implementation of a dual data protection organisation with a coordinator and a DPO?

Successfully implementing a dual data protection organisation requires a well-considered balance between legal requirements, organisational realities, and strategic objectives. Critical success factors encompass both structural and cultural aspects that must be systematically addressed.

🏗 ️ Structural success factors:

• Clear governance architecture: Establishment of unambiguous decision-making structures, reporting channels, and responsibility matrices that create optimal operating conditions for both roles.
• Resource adequacy: Appropriate provision of both functions with personnel, technical, and financial resources in line with their respective task profiles.
• Systemic integration: Embedding the dual structure into existing organisational processes and IT landscapes without disrupting operational workflows.
• Performance management: Development of role-specific KPIs and evaluation systems that make individual achievements and collaboration effects measurable.

🌟 Cultural and change management factors:

• Acceptance building: Systematic communication of the benefits of a dual data protection organisation to all stakeholder groups and active addressing of concerns.
• Competency development: Continuous training of both roles to ensure current expertise and effective collaboration.
• Trust and cooperation: Building trusted working relationships between the coordinator and the DPO through joint projects and structured collaboration.
• Continuous optimisation: Establishment of regular review processes to adapt the organisational structure to changing requirements and experiences.

How do organisations manage the particular challenges of coordinating between an internal data protection coordinator and an external DPO?

Coordination between an internal data protection coordinator and an external DPO brings specific challenges that go beyond normal internal collaboration. Successfully managing this constellation requires structured approaches and proven practices for external cooperation.

🔗 Particular challenges in an external DPO constellation:

• Information asymmetries: External DPOs naturally have less direct insight into internal processes and organisational culture, requiring intensive information preparation by the coordinator.
• Availability management: Coordination of different schedules and priorities between the internal organisation and the external resource.
• Confidentiality and security aspects: Ensuring appropriate information exchange while maintaining necessary confidentiality and data security.
• Cost-benefit optimisation: Efficient use of external DPO capacity through structured preparation and focused interactions.

💡 Proven solution strategies:

• Structured onboarding processes: Systematic introduction of the external DPO to organisational structures, processes, and culture by the coordinator.
• Regular communication rhythms: Establishment of fixed coordination appointments and structured reporting channels between both roles.
• Documentation standards: Development of uniform documentation and information standards that enable efficient knowledge transfer.
• Hybrid working models: Combination of various communication and collaboration formats (on-site, digital, asynchronous) for optimal collaboration.

What role do technological solutions play in supporting collaboration between the data protection coordinator and the DPO?

Technological solutions are critical for effective collaboration between the data protection coordinator and the DPO, as they enable structured communication, a shared data basis, and efficient workflows. Modern data protection organisations use integrated technology stacks to optimise their dual structures.

🖥 ️ Core technology setup for a dual data protection organisation:

• Integrated data protection management platforms: Central systems for records of processing activities, DPIA management, and compliance monitoring with role-specific access rights.
• Collaboration and communication tools: Modern platforms for structured collaboration, document exchange, and project-based cooperation.
• Dashboard and reporting systems: Intelligent dashboards that provide both roles with relevant KPIs and status information in real time.
• Workflow management systems: Automated process support for typical data protection workflows with clear task allocation between both roles.

⚡ Advanced technology features for optimised collaboration:

• AI-supported risk assessment: Intelligent systems for the automatic identification of data protection-relevant risks and corresponding task allocation.
• Integrated audit trails: Comprehensive documentation of all data protection-relevant activities of both roles for compliance evidence and continuous improvement.
• Mobile accessibility: Responsive platforms that provide both roles with flexible access to relevant information and functions.
• Integration into enterprise IT: Smooth connection to existing enterprise systems for automated data flows and reduced duplicate work.

How do organisations develop a sustainable succession planning strategy for both data protection roles?

A sustainable succession planning strategy for the data protection coordinator and the DPO is essential for continuous data protection compliance and organisational resilience. Given the critical importance of both roles, organisations must establish proactive succession planning and knowledge management systems.

📋 Strategic elements for sustainable succession planning:

• Competency mapping and transfer: Systematic documentation of all role-specific competencies, processes, and knowledge assets to ensure complete transferability.
• Talent pipeline development: Identification and continuous development of internal candidates for both roles through targeted training and mentoring programmes.
• Cross-training programmes: Training of staff in the fundamentals of both roles to create flexible cover capacity and improved role understanding.
• External partner networks: Building and maintaining relationships with qualified external candidates and consulting firms for emergency and transitional solutions.

🔄 Implementation of sustainable continuity structures:

• Knowledge management systems: Development of comprehensive documentation and knowledge databases that make critical know-how of both roles accessible and transferable.
• Phased handover processes: Structured transition procedures with overlapping working periods, mentoring, and gradual transfer of responsibility.
• Continuous competency development: Regular training and certification of all data protection staff to ensure current expertise.
• Organisational resilience: Development of redundant structures and backup systems that can bridge temporary staff absences without compliance risks.

What specific crisis management competencies do data protection coordinators and DPOs need in the event of data breaches, and how do they coordinate their response?

Data breach management requires precise role allocation and coordinated response between the data protection coordinator and the DPO. Both roles have specific responsibilities in a crisis situation that complement each other and together ensure comprehensive incident response.

🚨 Role-specific crisis management competencies:

• DPO responsibilities: Legal assessment of the incident, reporting obligations to supervisory authorities, strategic communication with senior management, and legal risk assessment.
• Coordinator tasks: Operational incident response coordination, technical damage limitation, internal communication with business units, and documentation of all measures.
• Shared responsibilities: Notification of data subjects, root cause analysis, development of preventive measures, and organisational learning from the incident.
• Escalation competencies: Structured decision-making on reporting thresholds, communication strategies, and resource allocation in a crisis situation.

⚡ Coordinated crisis response strategies:

• Incident response playbooks: Development of detailed process plans with clear task allocation, time requirements, and escalation mechanisms for both roles.
• Communication orchestration: Structured alignment between the operational coordinator perspective and the strategic DPO viewpoint for consistent crisis communication.
• Parallel workstreams: Simultaneous handling of operational and legal aspects by both roles with regular synchronisation and information exchange.
• Post-incident reviews: Joint follow-up of incidents for continuous improvement of crisis response capability and role optimisation.

How do international organisations structure the roles of data protection coordinators and DPOs taking into account different legal jurisdictions?

International organisations face the complex task of positioning data protection coordinators and DPOs in a multi-jurisdictional environment. This requires well-considered organisational structures that combine local legal requirements with global coherence.

🌍 Multi-jurisdictional challenges:

• Legal pluralism: Different data protection regimes (GDPR, CCPA, PIPEDA, etc.) require specific expertise and local adaptations of the role allocation.
• Compliance complexity: Coordination between global standards and local requirements through appropriate task allocation between central and decentralised functions.
• Cross-border coordination: Effective collaboration between coordinators and DPOs across different countries and legal jurisdictions.
• Cultural adaptation: Adapting role concepts to different organisational cultures and regulatory traditions.

🏗 ️ Structural solution approaches for global organisations:

• Matrix organisational models: Combination of global DPO functions with local coordinators for an optimal balance between standardisation and local compliance.
• Regional hub concepts: Establishment of regional data protection centres with specialised DPOs and coordinating functions for multiple countries.
• Competence centre approaches: Central pools of expertise for complex legal questions with decentralised operational implementation by local coordinators.
• Harmonised governance frameworks: Development of global standards and processes that integrate local particularities and enable effective collaboration.

What impact do new technologies such as AI and blockchain have on the role allocation between the data protection coordinator and the DPO?

New technologies such as AI and blockchain create additional complexity for data protection organisations and require adjustments to the role allocation between the coordinator and the DPO. Both functions must expand their competencies and develop new forms of cooperation.

🤖 Technology-specific challenges for data protection roles:

• AI governance: DPOs require deeper expertise in algorithmic transparency and fairness, while coordinators must implement operational AI compliance processes.
• Blockchain compliance: Special challenges in implementing data subject rights in immutable ledger systems require new expertise from both roles.
• IoT data protection: Coordination between strategic DPO advisory on IoT risks and operational coordinator implementation of device management processes.
• Cloud computing complexity: New requirements for data transfer assessments and processor management by both roles.

⚡ Adaptive role development for technology integration:

• Specialisation strategies: Development of technology-specific expertise within both roles or establishment of specialised support functions.
• Technology assessment processes: Structured evaluation procedures for new technologies with clear task allocation between strategic DPO analysis and operational coordinator implementation.
• Innovation-compliance balance: Development of frameworks that enable innovation while ensuring data protection compliance.
• Continuous competency development: Systematic training of both roles in emerging technologies and their data protection implications.

How do organisations assess and optimise the return on investment of their dual data protection organisation?

Assessing the ROI of a dual data protection organisation requires both quantitative and qualitative metrics that capture the added value of both roles. Successful organisations develop comprehensive business cases that take into account operational efficiency, risk reduction, and strategic advantages.

📊 ROI assessment dimensions for dual data protection structures:

• Cost savings: Reduction of fine risks, efficiency gains through specialisation, avoidance of duplicate work, and optimised resource utilisation.
• Process improvements: Accelerated decision-making, improved compliance quality, reduced error rates, and increased stakeholder satisfaction.
• Strategic advantages: Improved market positioning through data protection excellence, increased capacity for innovation, and strengthened reputation.
• Risk management: Quantification of avoided compliance risks, reduced audit efforts, and improved incident response times.

💰 Optimisation strategies for maximum ROI:

• Performance-based budgeting: Allocation of resources based on measurable performance indicators for both roles.
• Collaboration maximisation: Identification and utilisation of efficiency potential through optimised collaboration between the coordinator and the DPO.
• Technology investment: Strategic investment in tools and systems that support both roles and enable economies of scale.
• Continuous optimisation: Regular ROI reviews and adjustment of the organisational structure based on performance data and changing requirements.

What best practices have proven effective for performance measurement and continuous improvement of collaboration between the data protection coordinator and the DPO?

Performance measurement and continuous improvement of collaboration between the data protection coordinator and the DPO requires structured approaches that capture both individual performance and collaboration effects. Successful organisations implement comprehensive assessment and optimisation systems.

📈 Proven performance measurement frameworks:

• Balanced scorecard approaches: Integration of quantitative metrics (compliance scores, throughput times, cost savings) with qualitative assessments (stakeholder satisfaction, collaboration quality).
• 360-degree feedback systems: Comprehensive assessment of both roles by senior management, business units, external partners, and mutual evaluation.
• Outcome-based KPIs: Focus on end results such as compliance level, risk reduction, and organisational data protection maturity rather than activity measurements alone.
• Benchmark comparisons: Regular comparison with industry standards and best practice organisations for continuous performance optimisation.

🔄 Continuous improvement structures:

• Agile review cycles: Quarterly retrospectives with structured analysis of successes, challenges, and optimisation potential.
• Experimental approach: Systematic testing of new cooperation formats and working methods with measurable success evaluation.
• Learning communities: Building internal and external networks for continuous exchange of experience and best practice sharing.
• Feedback loops: Establishment of systematic feedback mechanisms between operational results and strategic adjustments to role design.

How do data protection coordinators and DPOs prepare for future regulatory developments, and how do they coordinate their continuing education?

Preparing for future regulatory developments requires proactive continuing education strategies and coordinated competency development between the data protection coordinator and the DPO. Both roles must continuously adapt their expertise to evolving legal requirements and technological developments.

🔮 Anticipatory competency development strategies:

• Regulatory intelligence: Systematic monitoring of regulatory trends, legislative processes, and supervisory authority developments with role-specific relevance assessment.
• Technology trend analysis: Continuous analysis of emerging technologies and their potential data protection implications for both role profiles.
• Scenario planning: Development of various future scenarios and corresponding competency requirements for strategic continuing education planning.
• Expert networks: Building and maintaining connections with regulators, academia, and industry experts for early insights.

📚 Coordinated continuing education architectures:

• Complementary learning paths: Alignment of continuing education activities of both roles to maximise the shared knowledge pool without redundancies.
• Shared learning programmes: Joint participation in conferences, seminars, and certification programmes with subsequent knowledge transfer.
• Internal knowledge sharing: Regular internal knowledge sessions in which both roles share and discuss their specialised insights.
• Professional development planning: Structured career development plans that connect individual strengths with organisational requirements and future challenges.

What challenges arise in the transition from a single-person data protection function to a dual organisation, and how is this change process optimally managed?

The transition from a single-person data protection function to a dual organisation with a coordinator and a DPO is a complex change process that requires structured management and sensitive communication. Successful transformations take into account both organisational and human factors.

🔄 Typical transformation challenges:

• Role redefinition: Transitioning from an all-round data protection function to specialised roles requires reorientation and potentially competency development.
• Acceptance management: Overcoming resistance to structural changes and concerns about loss of authority or restriction of competencies.
• Cultural adaptation: Developing a culture of cooperation in an area traditionally dominated by individuals.
• Resource reallocation: Redistribution of budgets, technologies, and access rights in line with the new organisational structure.

🌟 Proven change management strategies:

• Participatory approach: Involving the existing data protection function in the planning and design of the new structure to increase acceptance.
• Phased implementation: Gradual transition with pilot phases and continuous adjustment based on experience and feedback.
• Competency bridging: Systematic analysis of existing skills and targeted training to prepare for the new role allocation.
• Communication-intensive support: Regular information to all stakeholders on progress, challenges, and successes of the transformation process.
• Success story development: Early identification and communication of quick wins to motivate and build credibility for the new structure.

How do organisations develop a future-proof data protection organisation that can respond flexibly to changing roles of the coordinator and the DPO?

Developing a future-proof data protection organisation requires adaptive structures that can adjust to changing regulatory, technological, and business requirements. Successful organisations build flexibility and learning capability into their data protection architecture.

🏗 ️ Principles of a future-proof data protection organisation:

• Modular structures: Development of flexible organisational units that can be expanded, reduced, or reconfigured according to requirements.
• Skill-based flexibility: Building broad competency portfolios in both roles that enable rapid adaptation to new challenges.
• Technology-enabled adaptability: Implementation of flexible technology platforms that can support various organisational models.
• Cross-functional integration: Close interlinking of the data protection organisation with other organisational functions for increased adaptability.

🚀 Strategic future readiness approaches:

• Scenario-based planning: Development of multiple future scenarios and corresponding organisational models for various regulatory and technological developments.
• Continuous learning architecture: Establishment of systematic learning and adaptation mechanisms that enable organisational evolution.
• Innovation lab concepts: Creation of experimental areas for testing new forms of cooperation and working methods between the coordinator and the DPO.
• Partner ecosystem development: Building flexible networks of external partners and experts to supplement internal capacity as needed.
• Resilience building: Development of redundant structures and backup systems that ensure organisational continuity even in the event of fundamental changes.

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