In today’s data-driven world, businesses are expected to do more than deliver high-quality products or services – they’re also expected to handle personal data with care, transparency, and legal compliance. Whether you’re running a fast-growing tech startup, managing a mid-sized e-commerce store, or leading a well-established corporation, privacy compliance is no longer optional.

At the heart of effective privacy and GDPR compliance sits a key role: the Data Protection Officer (DPO). This is the person who ensures your organisation collects, stores, and processes personal data in a lawful, secure, and transparent way. For many businesses, especially those that don’t have in-house expertise, the best solution is to hire an external or outsourced DPO – a specialist who can guide your business without the cost of a full-time internal position.

1. When Is a DPO required under GDPR?

The General Data Protection Regulation (GDPR) makes it mandatory to appoint a DPO in certain situations. You must have a DPO if:

  • You operate as a public authority or body (except for courts acting in a judicial capacity)
  • Your core activities involve large-scale processing of sensitive personal data (e.g., health data, biometric data, political opinions, or religious beliefs)
  • You regularly and systematically monitor individuals on a large scale (for example, through online tracking, user profiling, or location tracking via mobile apps)

This means that a social media platform, a health-tech company processing medical data, or an analytics business conducting large-scale user tracking is legally obliged to have a DPO.

Importantly, GDPR applies extraterritorially – so even if your business is outside the EU, you must comply if you handle the personal data of EU residents.

Why voluntary appointments are on the rise:
Many businesses appoint a DPO voluntarily even when not strictly required to do so. Why? Because having a dedicated data protection expert reduces compliance risk, strengthens customer trust, and ensures the business can respond quickly to privacy issues or audits. An outsourced DPO is often the most cost-effective way to achieve this.

2. Why many businesses choose an External or Outsourced DPO

While the GDPR requires some organisations to appoint a DPO, it does not specify that the role must be held by an employee. This flexibility means that businesses of all sizes can meet their obligations by using an external or outsourced Data Protection Officer – a solution that is growing in popularity across the EU, the UK, and globally.

For startups, SMEs, and even larger companies without in-house privacy expertise, the appeal of an outsourced DPO is clear: you get the expertise you need without the cost and administrative burden of a full-time hire.

Here are the most common reasons businesses choose an external DPO:

  • Cost-effectiveness: Hiring a qualified, in-house DPO is expensive. Salaries for experienced privacy professionals are high, and you must also cover benefits, training, and equipment. With an outsourced DPO, you only pay for the level of support you actually need – whether that’s a few hours a month or full-scale ongoing assistance.
  • Guaranteed independence: GDPR requires that the DPO operates independently, without conflicts of interest. In small and mid-sized companies, it can be challenging for an internal DPO to stay fully independent if they are also handling other business tasks. An external DPO avoids this conflict entirely.
  • Specialist expertise: Outsourced DPOs are often seasoned privacy professionals with legal, technical, and regulatory backgrounds. They are familiar with multiple industries – such as healthcare, finance, SaaS, and e-commerce – which means they bring practical, tested solutions rather than theory alone.
  • Scalability and flexibility: Your data protection needs may change over time – especially if your business grows, enters new markets, or expands its data processing activities. An outsourced DPO can adjust their service level as your needs evolve, without the HR complexities of scaling an in-house role.
  • Immediate availability: Recruiting the right internal DPO can take months. With an external provider, you can start working on your GDPR compliance within days, avoiding delays that might otherwise put you at risk.
  • Access to resources and tools: Many outsourced DPOs bring access to advanced compliance management systems, templates, and legal monitoring services that would be costly for an individual company to set up independently.

Example:
A medium-sized e-commerce company in Romania processes thousands of customer orders every month, including payment and delivery information. While GDPR does not mandate a full-time DPO for them, the complexity of their operations and their cross-border customer base creates significant compliance risks. By outsourcing to an external DPO service, they meet GDPR expectations, get expert guidance, and pay only for a package suited to their workload -rather than hiring an expensive full-time employee.

This combination of expertise, flexibility, and cost savings is why external DPO services are now widely adopted not only by smaller businesses but also by large corporations seeking specialised support for complex projects.

3. What does a DPO actually do?

Whether internal or outsourced, the Data Protection Officer (DPO) is the central point of expertise and accountability for data protection in your organisation. Under Article 39 of the GDPR, their role is clearly defined, but in practice, a good DPO will go far beyond the legal minimum to ensure your business is proactive, compliant, and prepared.

Here’s what a DPO – especially an external DPO service provider – will typically handle:

  • Advise on GDPR and national data protection laws
    The DPO ensures that management and employees understand their obligations under applicable privacy laws. This includes explaining GDPR principles, lawful bases for processing, consent requirements, and retention rules in a way that’s practical and easy to follow.
  • Develop and monitor internal privacy policies
    The DPO will help you create clear, actionable policies covering how personal data is collected, stored, accessed, shared, and deleted. They’ll also make sure these policies are reviewed regularly to keep up with legal and business changes.
  • Train your team
    GDPR compliance isn’t just the responsibility of one person – it’s a company-wide effort. The DPO will provide staff training, from onboarding sessions to annual refreshers, ensuring every employee understands how to handle personal data correctly.
  • Oversee Data Protection Impact Assessments (DPIAs)
    For high-risk processing – such as introducing new tracking technologies, launching an AI-based service, or entering a new market – the DPO will guide you through DPIAs to identify and minimise potential privacy risks before they become problems.
  • Serve as your contact with supervisory authorities
    The DPO is the official point of contact for data protection authorities (DPAs) during inspections, investigations, or breach notifications. This means they speak the regulator’s language and ensure all communications are accurate and timely.
  • Handle data subject requests
    Whether it’s a request for data access, correction, deletion, or portability, the DPO coordinates and documents the process to ensure compliance with GDPR deadlines and requirements.
  • Coordinate breach response
    In the event of a data breach, the DPO will assess the severity, determine reporting obligations, guide the technical response, and prepare notifications to regulators and affected individuals where required – all within the strict GDPR timelines.
  • Provide ongoing compliance monitoring
    Compliance isn’t a one-off project. An outsourced DPO will regularly review your operations, update policies, and test security measures to ensure you remain compliant as laws and technologies change.

Example:
A mobile app company launches a new AI-powered feature that personalises user recommendations based on behaviour tracking. Before release, their outsourced DPO conducts a DPIA, flags areas where the privacy notice needs updating, advises on minimising data collection, and ensures the new feature has appropriate consent and opt-out mechanisms in place. This not only reduces legal risk but also demonstrates transparency to users.

An effective DPO acts as a bridge between legal, technical, and operational teams, ensuring that privacy isn’t an afterthought – it’s built into every part of your business.

4. Internal vs External DPO –which is better for your business?

When deciding whether to appoint an internal Data Protection Officer or engage an external (outsourced) DPO service, the right choice depends on your organisation’s size, resources, and the complexity of your data processing activities. Both options can fulfil the GDPR’s legal requirements, but each comes with its own advantages and limitations.

Internal DPO – Pros and Cons
An internal DPO is an employee who works exclusively for your organisation. They can be a full-time hire or have other responsibilities alongside their DPO duties (provided there’s no conflict of interest).
Advantages:

  • Full integration into your company culture and processes
  • Immediate access to internal systems and teams
  • Direct insight into daily operations and decision-makingDisadvantages:
  • High recruitment and salary costs – especially for experienced privacy professionals
  • Potential conflicts of interest if the DPO also has other roles (e.g., head of IT or marketing)
  • Ongoing training costs to keep up with changing laws and technologies
  • Limited exposure to different compliance approaches from other industries

External / Outsourced DPO – Pros and Cons
An external DPO is an independent professional or firm contracted to carry out all the responsibilities of the DPO role under GDPR.
Advantages:

  • More cost-effective – pay only for the level of service you need
  • Guaranteed independence, with no internal role conflicts
  • Access to a wider pool of expertise and industry best practices
  • Scalable services- you can expand or reduce support as your business changes
  • No recruitment delays – services can start almost immediately
    Disadvantages:
  • May require more onboarding to understand your business processes (though experienced providers have efficient discovery processes)
  • Less immediate availability for in-person tasks if they are off-site

Which is right for you?

  • If your organisation has a large, complex data processing operation and can afford a full-time specialist, an internal DPO may be a good fit.
  • If you are a small to medium-sized business, a startup, or an organisation without dedicated privacy expertise, an external DPO is often the smarter, more cost-effective choice – meeting GDPR obligations without the long-term financial commitment of a permanent hire.

Example:
A SaaS company serving customers across the EU and US opts for an outsourced DPO service. This gives them 24/7 access to privacy expertise, regular policy reviews, and GDPR audit support – all for less than half the cost of hiring a full-time internal DPO.

5. Why appointing a DPO sends the right message

In today’s business environment, where data breaches make headlines and regulators are actively enforcing GDPR, appointing a Data Protection Officer – especially through a reputable external DPO service – isn’t just about ticking a compliance box. It’s a public commitment to privacy, trust, and accountability.

Building customer confidence
Modern consumers are increasingly aware of their privacy rights. They pay attention to how businesses collect, store, and use their data. When you clearly identify your DPO – on your website, in your privacy policy, and in your communications – it signals to customers that:

  • You value transparency in data processing
  • You have a dedicated point of contact for privacy concerns
  • You take GDPR compliance and user rights seriously

Strengthening relationships with partners and clients
For B2B companies, having a named DPO can be a competitive advantage in contract negotiations. Many larger clients, especially in regulated sectors like healthcare, finance, or technology, require their vendors to have robust data protection governance. Being able to point to a professional, independent DPO – whether internal or outsourced – can speed up procurement processes and instill confidence.

Proactive risk management
A visible, active DPO presence demonstrates that your business isn’t waiting for problems to arise before acting. This reassures stakeholders – whether investors, customers, or regulators – that your company is committed to proactive compliance and early risk detection.

Reputation protection
In a world where one mishandled privacy request or late breach notification can damage your brand, having a DPO ensures your business is ready to respond effectively. Even if an incident occurs, the way you handle it – swiftly, transparently, and in line with GDPR – can preserve or even strengthen public trust.

6. Need an external DPO? We can help

If you’re unsure whether your business is legally required to have a Data Protection Officer, or if you already know you need one but don’t have the resources for an in-house hire, we can help you meet your obligations quickly and cost-effectively.

Our external DPO services are designed for startups, SMEs, and international organisations that want professional GDPR compliance support without the cost of a full-time employee. We act as your dedicated Data Protection Officer, fulfilling all the responsibilities under Article 39 of the GDPR while tailoring our services to your business model, sector, and risk profile.

Our outsourced DPO services include:

  • Full GDPR compliance oversight across your organisation
  • Monitoring and reviewing internal data protection policies and processes
  • Providing ongoing legal, technical, and operational advice on privacy matters
  • Serving as the official contact point for supervisory authorities (e.g., ANSPDCP in Romania, ICO in the UK)
  • Handling Data Subject Access Requests (DSARs) and other rights requests efficiently and lawfully
  • Conducting Data Protection Impact Assessments (DPIAs) for new projects, systems, or technologies
  • Coordinating breach response and reporting within GDPR deadlines
  • Delivering staff training to ensure your team understands their data protection responsibilities

Why choose us as your outsourced DPO?

  • Cost-effective: Get senior-level expertise for a fraction of the cost of a full-time hire
  • Independent and conflict-free: Meet GDPR’s independence requirement without internal role conflicts
  • Industry experience: We’ve worked with businesses in technology, healthcare, finance, retail, and beyond
  • Scalable support: Increase or reduce service levels as your business evolves
  • Immediate availability: We can start supporting your compliance within days, not months

Appointing us as your external Data Protection Officer ensures you have a trusted partner to safeguard your compliance, manage your privacy risks, and give your customers confidence in your data handling.

Contact us today to discuss your needs and find the right outsourced DPO package for your business.