Outsourced DPO service

Appoint your Data Protection Officer

Independent, outsourced DPO for organisations that need expert data protection oversight — without the overhead of a full-time hire.

Talk to us
Article 37 GDPR

Do you need a Data Protection Officer?

GDPR requires a DPO in specific circumstances. Many organisations also appoint one voluntarily to strengthen their privacy programme.

Mandatory

Public authority or body

All public authorities and bodies that process personal data must designate a DPO, regardless of the type of data they process.

Mandatory

Large-scale systematic monitoring

Your core activities require regular and systematic monitoring of data subjects on a large scale — behavioural tracking, profiling, location monitoring.

Mandatory

Special category data at scale

Core activities involve large-scale processing of health, biometric, genetic, racial, ethnic, political, or religious data.

Good practice

Client or investor expectation

Partners expect a designated DPO as part of vendor due diligence, procurement questionnaires, or funding conditions.

Good practice

Multi-jurisdiction processing

You process personal data across multiple EU/EEA member states and need a single point of coordination for supervisory authorities.

Good practice

Growing complexity

New products, AI deployments, cross-border transfers — expert oversight before complexity becomes a compliance gap.

Across the regulation

The DPO in the GDPR

The Data Protection Officer isn't mentioned in one article. The role is woven across fifteen articles and two recitals.

Designation

Art. 37
Designation of the DPO — when required, who qualifies, group appointments
Art. 38
Position — independence, no instructions, resources, no dismissal for performing tasks
Art. 39
Tasks — inform, advise, monitor compliance, DPIA advisory, SA cooperation
Recital 97
Independence guarantee — duties performed in an independent manner

Transparency

Art. 13
Privacy notice (direct collection) — must include DPO contact details
Art. 14
Privacy notice (indirect collection) — must include DPO contact details
Art. 30
Records of processing — shall contain DPO contact details

Accountability

Art. 35
DPIA — controller shall seek the advice of the DPO
Art. 36
Prior consultation — DPO contact details required in SA submission
Art. 33
Breach notification — must include DPO contact in SA notification
Art. 47
Binding corporate rules — must specify DPO tasks

Supervision

Art. 57
SA tasks — DPO as contact point for the supervisory authority
Recital 77
Risk assessment — DPO indications on proportionate measures

"Your Data Protection Officer isn't a compliance checkbox. The role is referenced across fifteen articles of the GDPR — from how you write your privacy notice to how you report a breach. That's why it matters who holds it."

Service scope

What your DPO does for you

A named DPO with the professional expertise, resources, and independence that Articles 37–39 require.

Formal designation

We register your DPO appointment with the relevant supervisory authority and publish the contact details as required by Articles 13, 14, and 37(7).

Ongoing advisory

Practical, ongoing guidance on data protection obligations — not annual check-ins, but available when decisions are being made.

Supervisory authority liaison

Your designated contact point for data protection authorities. We handle enquiries, prior consultations, and regulatory correspondence.

Data subject requests

Contact point for data subjects exercising their rights. We triage, advise on response, and track compliance with statutory timelines.

DPIA review

Advisory on Data Protection Impact Assessments — when one is needed, how to conduct it, and what the findings mean for your processing.

Breach support

Guidance on breach assessment, notification obligations under Article 33, and communication to affected individuals under Article 34.

Compliance monitoring

Ongoing monitoring of your processing activities against your obligations, with regular reporting to your leadership.

Training advisory

Guidance on awareness and training for staff involved in processing operations, tailored to your actual processing activities.

Process

How it works

From first conversation to formal DPO designation — typically within two weeks.

Assessment

We evaluate your processing activities, data landscape, and existing privacy programme to understand your requirements.

Proposal

A clear scope of service, a named DPO with relevant sector experience, and straightforward pricing. No hidden costs.

Appointment

Formal designation with the relevant supervisory authority. Your privacy notice and documentation updated with DPO contact details.

Ongoing service

Your DPO is available for advisory, liaison, and compliance oversight. Regular reporting on the state of your data protection programme.

Coverage

Jurisdictions

DPO appointment across multiple data protection frameworks, from a single provider.

European Union

GDPR — Articles 37–39

DPO designation for controllers and processors subject to EU GDPR. Registration with the relevant member state supervisory authority. All 27 EU member states from a single appointment.

United Kingdom

UK GDPR — Articles 37–39

DPO designation under the UK's retained GDPR framework. Registration with the ICO. Aligned with EU requirements for organisations operating across both jurisdictions.

Brazil

LGPD — Article 41

Encarregado pelo tratamento de dados pessoais — the Brazilian equivalent of a DPO under the Lei Geral de Proteção de Dados. Appointment and registration with the ANPD.

Independence by design

Article 38(3) GDPR requires that a DPO receives no instructions regarding the exercise of their tasks, reports to the highest level of management, and is protected from dismissal or penalty for performing their role. These are not aspirations — they are the conditions of the appointment.

Our engagement structure is built around them: your DPO advises independently, escalates directly, and holds no other role in your organisation that could create a conflict of interest under Article 38(6).

Articles 38–39 GDPR · Recital 97
Questions

Frequently asked questions

Can a DPO be outsourced?

Yes. Article 37(6) GDPR explicitly provides that the DPO may be a staff member or may fulfil the tasks on the basis of a service contract. An outsourced DPO must meet the same professional quality, expert knowledge, and independence requirements as an internal appointment.

What qualifications does the DPO need?

Article 37(5) requires the DPO to be designated on the basis of professional qualities, in particular expert knowledge of data protection law and practices. There is no mandatory certification, but practical experience in data protection compliance, regulatory engagement, and the relevant sector is essential.

Can our DPO hold other roles in our organisation?

Only if those roles create no conflict of interest. Article 38(6) permits a DPO to fulfil other tasks, but the controller must ensure they do not result in a conflict — which is why roles that determine the purposes and means of processing (such as head of IT, HR, or marketing) are generally considered incompatible. An external DPO avoids this problem structurally: their only role in your organisation is the DPO role.

How quickly can a DPO be appointed?

Typically within two weeks of engagement. The assessment and proposal phase takes a few days, followed by formal designation with the relevant supervisory authority. We can accommodate urgent timelines where needed — for example, ahead of a procurement deadline or regulatory filing.

What does the DPO service cost?

Pricing depends on the complexity of your processing activities, the number of jurisdictions, and the level of ongoing advisory support required. Contact us for a proposal tailored to your organisation. No hidden costs and no lock-in beyond the agreed service period.

Do we still need a DPO after the UK's data protection reforms?

The UK's Data Protection and Digital Information Act introduced the role of "senior responsible individual" to replace the DPO in some contexts. However, if you also process EU data, the EU GDPR DPO requirement remains unchanged. We advise on both frameworks and can help you determine what is needed for your situation.

Get started

Tell us about your organisation and we will be in touch within one working day.

Your enquiry is processed by Sovy Trust Solutions Limited to respond to you and prepare a proposal. Details in our Privacy Notice.