Data Protection Officer (DPO) Outsourcing

Company Hired Full-Time DPO - Idle 80% of the Time

A manufacturing company hired DPO full-time (€2,500/month gross + employer costs = €3,500/month). 80% of the time DPO had no specific tasks - monitored, read, waited. Actual tasks (audits, training, breaches) took 2-3 days monthly. Annual cost: €42,000 for work worth €10,000.

Problem with in-house DPO:

• Employment cost: €30,000 - €45,000 yearly (+ recruitment, training, leave)
• No continuity - vacation, illness, termination = no DPO
• Limited experience - 1 person, 1 industry, 1 perspective
• Difficult recruitment - shortage of GDPR specialists

External DPO - Full Function for Fraction of Cost

You get a dedicated Data Protection Officer with experience in dozens of GDPR projects - without employment, recruitment and training costs. You pay predictable monthly fee, have expert access when needed.

What you get:

• Data Protection Officer function per GDPR Art. 37-39
• Formal appointment and registration with authority (if required)
• GDPR compliance oversight and monitoring
• Data protection advisory (ongoing)
• Data breach handling (24/7) - authority notifications within 72h
• Authority cooperation as contact point
• Processing activities register support
• Periodic GDPR audits (1-2 times per year)
• Training for employees and management (GDPR awareness)
• Support in exercising data subject rights (access, erasure, rectification)
• Processing agreement and vendor compliance review
• GDPR documentation updates (policies, procedures)
• Monthly compliance reports for management

Who Is It For?

This service is for you if:

• You must have DPO (public body, sensitive data, monitoring) but don’t want to hire
• You want DPO voluntarily for order and compliance
• You have DPO but need backup/support (vacations, absences)
• You don’t have budget for full employment €2,500+/month
• You need GDPR experience without months of recruitment

When Must You Have a DPO?

Mandatory (Art. 37 GDPR)

1. Public authorities and bodies

• Government and local administration
• Offices, ministries, agencies
• Public schools, hospitals, universities
• Social security, health service, police, courts

Exception: Courts exercising judicial functions (don’t need)

2. Regular and systematic monitoring On large scale as core activity:

• Employee monitoring (location, email/web monitoring)
• CCTV in stores, offices
• Online behavior tracking (advertising tech)
• Profiling and credit scoring

Criteria: “regular” = continuous/repeated, “systematic” = methodical, “large scale” = large number of people

3. Large scale processing of sensitive data Special category data (Art. 9 GDPR):

• Health data (hospitals, clinics, laboratories)
• Genetic and biometric data
• Racial or ethnic origin
• Religious or philosophical beliefs
• Political opinions
• Sexual orientation
• Trade union membership
• Criminal conviction and offense data

Criteria: “large scale” = hundreds/thousands of people, as core activity

Can You Have DPO Voluntarily?

YES! Even if not required, you can appoint DPO voluntarily for:

• Organizing GDPR compliance
• Building customer and partner trust
• Preparing for authority inspections
• Supporting team on GDPR topics

DPO Duties (Art. 39 GDPR)

1. Informing and Advising

• Advisory for controller and employees on GDPR
• Answering data protection questions
• Training and building awareness

2. Monitoring Compliance

• GDPR and local law compliance oversight
• Monitoring data protection policy implementation
• Documentation review and updates
• Compliance audits and assessments

3. Cooperation with Supervisory Authority

• Contact point for authority
• Consultation on inspections and notifications
• Cooperation in investigations

4. DPIA Advisory

• Support with Data Protection Impact Assessments
• DPIA execution monitoring

Cooperation Models

DPO Basic

For small organizations with simple processing:

• DPO function fulfillment
• Email/phone consultations (up to 4h monthly)
• 24/7 breach handling
• Annual compliance report
• 1 awareness training yearly

Price: €500-750/month

DPO Standard

For medium organizations with larger scope:

• Everything from Basic
• Consultations (up to 8h monthly)
• GDPR audit once yearly
• Quarterly documentation review
• Data subject rights support
• Quarterly report
• 2 trainings yearly

Price: €1,000-1,500/month

DPO Premium

For large organizations or demanding compliance:

• Everything from Standard
• Consultations (up to 16h monthly)
• GDPR audit 2x yearly
• Monthly documentation review
• DPIA for new processes
• Authority representation
• Monthly report
• 4 trainings yearly
• Dedicated account manager

Price: €2,000-3,500/month