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Services / DPO Services — EU & UK GDPR

Outsourced DPO services — independent, and practical

An outsourced DPO is a data protection officer appointed from outside your organisation — the role the GDPR requires, held by a specialist rather than a member of your staff.

Independent mandateKPIs & risk registerEvidence pack ready
Speak to a DPO specialistSee what’s included

No automated signup — short discovery, clear scope, and a proposal aligned to your markets.

Acting for a client? We are appointed behind professional advisers and report to you. Your relationship with your client stays yours.

Do you need a DPO? Run the two-minute check

Interactive Article 37 trigger check — result first, nothing stored, no email required.

What drives DPO pricing

Retainer vs ad-hoc, the factors that move cost, and how to get a scoped quote.

You need one if you are a public authority, if your core activities require large-scale regular monitoring of people, or if you process criminal or special-category data at scale. Many organisations appoint one voluntarily because a regulator, a customer or an investor asked. Run the two-minute check.

Privacy Core Services holds the role for you: named contact for your supervisory authority, board-ready reporting, and the written evidence that shows the role is genuinely independent.

Why your DPO cannot report to the person they audit

Article 38(6) of the GDPR permits a DPO to hold other duties — but only where those duties create no conflict of interest. In practice that rules out most of the people organisations first think of. A head of IT, a head of HR, a general counsel or a managing director all determine the purposes and means of processing. They cannot credibly audit decisions they made themselves, and regulators have said so.

That is the structural reason to appoint from outside. An outsourced DPO has no reporting line into your operations, no budget to defend and no internal decision to protect — which is exactly what Article 38 asks for and what a supervisory authority looks for when it examines the appointment.

Article 37(6) permits the role to be filled under a service contract. Appointing externally is not a workaround; it is the route the regulation names.

Outsourced DPO, or DPO as a service, vs internal vs ‘privacy lead’

Outsourced DPOInternal hire'Privacy lead' (no DPO)
IndependenceStructurally independent — no other role in the organisation to conflict withAchievable, but hard in small teams where the DPO also owns processing decisionsNot a DPO: no statutory role, no protected independence
Expertise & coverSenior practitioner plus team; holiday and absence coveredOne person's bandwidth and specialism; cover is your problemVaries; usually privacy is a fraction of their job
Cost shapePredictable retainer, scales with needFull salary + training + tooling for a role many SMEs cannot fill full-timeHidden: unmanaged risk and rework
When it fitsArt. 37 trigger applies, or you want the discipline without the headcountLarge-scale, complex processing that needs a daily on-site presenceOnly where no trigger applies and risk is genuinely low — check first

What drives the cost of each model: DPO pricing, explained honestly.

Outcomes

Governance outcomes you can show

Independent oversight with evidence, cadence, and reporting that stands up to scrutiny.

Independent oversight

Clear mandate and reporting line, separated from day-to-day operations and conflicts.

Evidence-ready posture

RoPA, DPIAs/TIAs, DSAR and incident logs, vendor records, and training evidence.

Board-ready governance

KPIs, risk register, and structured reporting directors can act on.

Designed to meet EU / UK GDPR DPO expectationsAligned with security, risk, and audit functions

Scope

What’s included as standard

Core governance deliverables that stay maintainable — not shelfware.

Mandate & reporting line

Document independence, responsibilities, escalation path and comms routes.

Registers & formal advice

Support for RoPA, DPIAs/TIAs, DSAR & incident workflows with DPO opinions when needed.

Vendor & stakeholder support

Input on DPAs, DDQs, security reviews and customer / regulator queries.

Incident & breach readiness

Playbooks, sign-off patterns, regulator thresholds and evidence for decisions.

Ongoing advisory

Email support with agreed turnaround; optional office hours and enablement.

Governance reporting

Quarterly/semi-annual reporting on KPIs, risks, actions and remediation progress.

Request DPO support

Clarity

How DPO support works in practice

Clear delivery expectations — and what typically goes wrong elsewhere.

CapabilityOur approachTypical alternatives
IndependenceFormal mandate, conflict management, direct reporting line.Unclear role; DPO wearing multiple conflicting hats.
Registers & evidenceStructured RoPA, DPIAs, DSAR & incident logs with audit trail.Scattered docs in shared drives/spreadsheets.
Board engagementRegular reporting with KPIs, risks and actions.Ad-hoc updates after issues arise.
Support modelPragmatic advisory aligned to delivery cycles.Purely legal memos disconnected from reality.
Regulator & buyer postureEvidence pack ready for regulators and procurement.Last-minute scramble to answer questionnaires.
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FAQ

Questions, answered

Clear answers to the objections we hear most.

Do we actually need to appoint a DPO?
If your core activities involve large-scale monitoring or special category data, a DPO is often required. We can assess and document the rationale either way.
Can you be both DPO and consultant?
We preserve independence. Where there’s a conflict of interest, advisory work is separated from the DPO mandate or delivered by a different team member.
Can you cover both EU and UK GDPR?
Yes. We can provide DPO support across EU and UK regimes, and combine this with Representative services if you lack local establishment.
Will this slow product or sales down?
No. We align governance to delivery and sales cycles, focusing on the highest-risk areas first and giving clear, pragmatic guidance.
Is an outsourced DPO actually allowed?
Yes — Article 37(6) expressly allows the DPO to act under a service contract. What matters is that the DPO is genuinely involved, resourced and independent; the regulation cares about the function, not the employment relationship.
How is independence protected?
The DPO cannot be instructed on how to advise, cannot be penalised for advice, and must avoid conflicting duties. An external DPO makes the conflict test structurally easier: we hold no other role in your organisation, and our engagement terms carry the EDPB's conflict-of-interest requirements verbatim.
What if we already have someone doing privacy internally?
That often works well together: your internal lead keeps operational ownership while the outsourced DPO provides the statutory role, independence and second pair of senior eyes. The comparison above shows where each model fits.
Which regulators can you deal with?
EU supervisory authorities and the UK ICO. Where you need an Article 27 representative as well — a separate role from the DPO — we provide that through our EU and UK representative service, and the same team keeps both consistent.
How quickly can a DPO be in place?
Appointment is typically live within days of the scoping call: naming, notification and register handover are the critical path, and none of them are slow.
Need a quick assessment? We can document whether you require a DPO and the rationale either way.

Related services

Next step

Request DPO support

Share your markets, resourcing, and risk profile. We’ll reply with a scoped plan and clear proposal.

Ask for outsourced/virtual DPO, support for an internal DPO, or a one-off assessment.

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