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External Data Protection Officer (DPO)

We can act as your external Data Protection Officer under the GDPR.

External Data Protection Officer

Organisations that process personal data at scale need a Data Protection Officer who can combine legal judgement, operational understanding and independence. We act as an external DPO under the GDPR for companies that need experienced privacy leadership without building a full internal function. Our support helps management teams maintain oversight, prioritise privacy risks and turn data protection requirements into practical governance.

External Data Protection Officer as a Service

A DPO role is not only a formal GDPR appointment. Done well, it gives the organisation a structured way to identify risk, challenge decisions, support teams and demonstrate accountability to customers, regulators and the board.

We provide outsourced and interim DPO support for start-ups, SMEs, international groups and listed companies. Our experience covers SaaS, cloud infrastructure, digital marketing, e-commerce, healthcare, software products, hardware manufacturers and other organisations where data protection is closely connected to product development, customer delivery and commercial growth.

As external DPO, we provide independent advice, ongoing monitoring and practical support across the organisation. This includes privacy governance, risk assessments, DPIAs, vendor and processor management, data breach handling, data subject rights, staff training, international transfers, marketing compliance and communication with supervisory authorities and data subjects.

When external DPO support creates value

Many organisations appoint a DPO because they have to. The real value comes when the role is connected to how the business actually works.

Common situations include:

  • rapid growth without a mature privacy function;
  • enterprise customers requesting stronger GDPR governance;
  • international expansion and complex data flows;
  • new AI, analytics, marketing or platform initiatives;
  • a temporary gap before recruiting an internal DPO;
  • a need to restart or professionalise the privacy programme;
  • board or management concern that GDPR accountability is too dependent on isolated documents.

In these situations, external DPO support gives the organisation senior expertise, independence and continuity without the cost or delay of building the full function internally.

Our engagement journey

1. DPO pre-study and onboarding

We normally start with a focused pre-study. This gives both management and the DPO function a clear view of the organisation’s processing activities, maturity level, key risks and immediate priorities.

The pre-study typically covers:

  • business model, products, services and data flows;
  • current GDPR governance, policies and documentation;
  • processor and supplier landscape;
  • marketing, analytics and customer data practices;
  • international transfers and Schrems II exposure;
  • information security and breach readiness;
  • previous incidents, complaints or regulatory contacts;
  • roles, responsibilities and reporting lines.

The result is a practical DPO onboarding report with prioritised findings, recommended first actions and a proposed operating model.

2. DPO operating model

We define how the external DPO role should work in practice. This includes reporting lines, escalation routines, meeting cadence, decision forums, documentation standards and how the DPO interacts with management, legal, compliance, security, marketing, product and customer-facing teams.

The aim is to make the DPO function visible, useful and proportionate — not a compliance layer that slows down ordinary business.

3. Ongoing advice and monitoring

We provide continuous DPO support based on the organisation’s risk profile and activity level. This may include monthly or quarterly check-ins, review of new initiatives, DPIA support, advice on customer and supplier questions, audit check-ups, training and review of privacy documentation.

We focus on the areas where the DPO can create the most value: early issue spotting, risk prioritisation, clear recommendations and practical follow-through.

4. Incident, authority and data subject support

When needed, we support the organisation in relation to personal data breaches, complaints, data subject requests, and supervisory authority dialogue. We help assess legal thresholds, prepare documentation, support internal decision-making and ensure that communications are accurate, timely and proportionate.

5. Strategic alignment and privacy restart

For organisations with fragmented or outdated GDPR work, we can use the DPO role to support a structured privacy restart. This may include refreshing the record of processing activities, updating key policies, improving vendor controls, reviewing marketing compliance, clarifying accountability and aligning privacy work with leadership priorities.

Why outsource the DPO role?

Independence and credibility

An external DPO can provide independent judgement and challenge decisions without being embedded in internal reporting conflicts. This strengthens GDPR accountability and gives management a clearer view of risk.

Senior expertise from day one

DPO competence is difficult to recruit and maintain internally. External support gives immediate access to experienced data protection lawyers with knowledge of GDPR, digital business models, technology, security expectations and regulatory practice.

Practical advice across functions

A good DPO must understand more than legal text. The role often touches product, engineering, information security, sales, procurement, HR, marketing and customer success. We help translate data protection requirements into actions those teams can apply.

Scalable and cost-efficient support

External DPO support can be scaled to the organisation’s needs. Some clients need a light-touch monitoring and advisory model. Others need interim DPO leadership, intensive remediation or support during growth, procurement, incidents or regulatory scrutiny.

Faster start than recruitment

Where the DPO role is vacant, under-resourced or newly required, external support can give the organisation a structured function quickly while long-term internal options are assessed.

Pricing model

We offer DPO support through a combination of fixed and volume-based pricing, depending on the organisation’s needs, complexity and preferred level of support.

A typical model includes:

  • a fixed onboarding or pre-study phase;
  • a monthly retainer for ongoing DPO availability, monitoring and reporting;
  • volume-based support for larger projects, incidents, DPIAs or regulatory matters.

This gives management predictability while allowing the DPO function to respond when more support is needed.

Typical deliverables

Depending on scope, our external DPO support may include:

  • DPO onboarding report and risk-prioritised roadmap;
  • DPO operating model and reporting structure;
  • regular DPO reports to management or the board;
  • review of records of processing activities;
  • DPIA and risk assessment support;
  • breach assessment and notification support;
  • data subject request support;
  • vendor and processor review;
  • Schrems II and international transfer advice;
  • marketing and cookie compliance support;
  • privacy training for key teams;
  • supervisory authority and data subject communication support.

First step a pre-study

The first step is usually a short scoping discussion followed by a DPO pre-study. This helps us understand your organisation, confirm whether an external DPO model is appropriate and define a level of support that fits your risk profile, resources and business priorities.

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No obligations for the first contact; clear costs; confirmation before billing starts and often fixed prices.
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