Article 38(3) GDPR provides that the data protection officer must not be dismissed or penalised by the controller or processor for performing the tasks. The protection is linked to the performance of those tasks. A measure taken in response to an unwelcome review, critical report or escalation therefore requires particularly careful organisational reasoning.
Not every personnel or financial decision involving the privacy function is automatically a penalty. Changes may have legitimate organisational reasons. The relevant factors include the occasion, timing, explanation and effect. If access, time, budget or reporting opportunities are withdrawn shortly after a critical report, the connection should be examined and documented.
The internal record should not consist only of an organisation chart. It should also show the tasks, agreed resources, reporting route and the objective reason for material changes. This creates a reliable basis for the continuing organisation of the role.