Frequently asked questions about outsourced DPO services

What is an outsourced Data Protection Officer?

An outsourced Data Protection Officer (DPO) is an external data protection professional appointed to perform the DPO role for an organisation. The outsourced DPO can fulfil the statutory responsibilities of the role while providing independent advice, oversight and specialist data protection expertise.

When does an organisation need to appoint a DPO?

Under the EU GDPR and UK GDPR, certain organisations are required to appoint a DPO, including public authorities and organisations whose core activities involve certain forms of large-scale monitoring or processing of special categories of personal data. 

Even where a DPO is not legally required, organisations processing personal data are still required to demonstrate compliance and so many choose to appoint a DPO as part of their data protection governance arrangements.

Can a Data Protection Officer be outsourced?

Yes. Both the EU GDPR and UK GDPR allow the DPO role to be performed by an external service provider, provided the relevant requirements of the legislation are met.

What does an outsourced DPO do?

An outsourced DPO can advise an organisation on its data protection obligations, monitor compliance, provide advice on DPIAs, support data breach and data subject request management, liaise with supervisory authorities and report to senior management.

The precise scope will depend on the organisation’s activities, risk profile and internal resources.

What are the benefits of outsourcing the DPO role?

Outsourcing can provide access to experienced data protection specialists without recruiting a full-time internal DPO. It can also provide greater independence, continuity, access to additional specialist resources and support during significant incidents or periods of increased demand.

How does an outsourced DPO service get started?

We begin by developing an understanding of your organisation, its data processing activities, regulatory environment and existing data protection arrangements. This can include reviewing key policies, procedures, records and previous assessments, as well as engaging with relevant stakeholders.

From there, we agree priorities and establish an appropriate model of ongoing DPO support, reporting and oversight based on your organisation’s requirements and risk profile.

What is the difference between an outsourced DPO and a data protection consultant?

A consultant may provide advice on individual data protection projects or issues. An outsourced DPO assumes an ongoing DPO role and the associated responsibilities, including independent oversight, monitoring compliance and acting as a point of contact with data subjects and supervisory authorities.

Can an outsourced DPO support organisations in both Europe and the UK?

Yes. Forvis Mazars supports organisations operating under both the EU GDPR and UK GDPR and can access additional privacy expertise through our international network where organisations operate across multiple jurisdictions.

Can an outsourced DPO help with a personal data breach?

Yes. An experienced DPO can help assess a personal data breach, advise on containment and remediation, determine whether regulatory or data subject notification may be required and support engagement with the relevant supervisory authority.

Can an outsourced DPO help with AI governance?

Yes. AI systems frequently involve the processing of personal data and can raise issues relating to transparency, lawful basis, automated decision-making, data minimisation and DPIAs.

Our DPO team can work alongside Forvis Mazars AI governance, cyber security and risk specialists to help organisations assess and manage these risks.

How does an outsourced DPO maintain independence?

A DPO must be able to perform the role independently and without instructions on how to carry out their statutory responsibilities. An outsourced arrangement can provide clear separation between the DPO’s oversight role and the organisation’s operational decision-making.

We establish appropriate governance and reporting arrangements so that the DPO has access to senior management, can raise issues independently and is appropriately involved in matters relating to the protection of personal data.

How does technology support the Forvis Mazars DPO service?

Our DPO specialists use technology and automation to support activities including DSAR management, ROPA development, DPA reviews, DPIAs, privacy notices and regulatory monitoring.

Technology helps reduce repetitive administrative activity, while our specialists retain responsibility for reviewing outputs, exercising professional judgement and providing advice.

How much does an outsourced DPO service cost?

The cost of an outsourced DPO depends on factors including the size and complexity of the organisation, the nature and volume of personal data processing, the level of regulatory risk, the jurisdictions involved and the amount of ongoing support required.

We tailor the scope of our service to the requirements and risk profile of each organisation.

What information does an outsourced DPO need access to?

An outsourced DPO needs sufficient access to relevant people, information and activities to understand how personal data is processed and to perform the role effectively.

Where available, this may include access to policies and procedures, Records of Processing Activities (RoPAs), DPIAs, data breach and data subject request records, contracts and other relevant documentation, as well as engagement with teams responsible for areas such as HR, IT, cyber security, legal, procurement and marketing. If these documents are not in place we will provide many of them as part of the service.

How do I choose an outsourced DPO provider?

Organisations should consider the provider’s experience, seniority, independence, regulatory knowledge, sector expertise, continuity arrangements and ability to respond to significant incidents.

For organisations operating across multiple jurisdictions or dealing with complex technology and regulatory issues, access to international and multidisciplinary expertise may also be important.

Does appointing an outsourced DPO transfer responsibility for data protection compliance?

No. Appointing an outsourced DPO provides independent advice, monitoring and oversight, but responsibility for complying with data protection legislation remains with the organisation.

The DPO works with management and relevant teams to identify risks, advise on obligations and support good data protection governance, while operational decisions and accountability remain with the organisation.