DPO as a service — a certified data protection officer, fractionally.
Outsourced Data Protection Officer under GDPR Article 37 — independent, certified, registered with your supervisory authority. The DPO function without the full-time hire.
Overview
An ongoing legal role, not a project-based engagement.
A Data Protection Officer is an ongoing, legally defined position under GDPR with specific obligations, independence protections, and a direct line to senior management and the supervisory authority. It is not a privacy consultant who delivers a defined piece of work and steps back — the DPO is a named individual with continuous accountability.
Cyber-Management's DPO as a Service provides that named, registered DPO on a fractional basis — satisfying the mandatory designation requirement at a cost accessible to SMBs, with the full independence and accountability GDPR Article 38 requires.
When a DPO is mandatory (Article 37)
Three triggers. If any one applies, designation is legally required.
Public authorities and bodies
All public authorities and bodies (except courts acting in their judicial capacity) — Article 37(1)(a).
Large-scale systematic monitoring of individuals
Behavioural advertising, location tracking, financial monitoring, employee surveillance at scale — Article 37(1)(b).
Large-scale processing of special-category or criminal data
Health, genetic, biometric, criminal convictions, religious beliefs, political opinions, sexual orientation — Article 37(1)(c).
Voluntary designation
Organisations may appoint a DPO voluntarily even when not required — many SMBs do, especially when clients demand it. The CNIL and other supervisory authorities actively encourage it.
The DPO function
Eleven statutory tasks under GDPR.
- 01
Advise the controller, processor, and employees
On obligations under GDPR and other data protection laws.
- 02
Monitor compliance with GDPR
Including responsibilities, awareness-raising, and training of staff involved in processing operations.
- 03
DPIA advisory and oversight
Provide advice on Data Protection Impact Assessments and monitor their performance.
- 04
Be the supervisory authority contact
Primary point of contact for the relevant supervisory authority — e.g. the CNIL in France, the BfDI in Germany, the AP in the Netherlands, the APD in Belgium, the Garante in Italy, the AEPD in Spain, the DPC in Ireland.
- 05
Be the data-subject contact
Designated contact for individuals exercising their data subject rights.
- 06
Support the ROPA
Develop and maintain Article 30 Records of Processing Activities.
- 07
International transfers oversight
Guide the organisation on lawful mechanisms for transferring personal data outside the EU/EEA.
- 08
Lead breach response
Breach assessment, 72-hour supervisory authority notification, individual notifications, breach register.
- 09
Deliver privacy training
Or commission and oversee training for all staff handling personal data.
- 10
Review privacy documentation
Privacy notices, data processing agreements, consent mechanisms.
- 11
Report to highest management
Direct reporting line. Cannot receive instructions on the exercise of DPO tasks (Article 38).
Penalties & consequences
Failure to designate is itself a violation.
Failure to designate a DPO when required under Article 37 is a GDPR violation in its own right — independent of any data breach or privacy incident. Article 83(4) sets the maximum at €10 million or 2% of total worldwide annual turnover, whichever is higher.
The CNIL, the ICO, and other EU supervisory authorities have all issued formal sanctions for non-designation. Beyond penalties, missing the DPO function compounds risk: data subject requests go unmanaged (further violations), breaches are reported late or not at all (higher-tier penalties), DPIAs for high-risk processing are not conducted.
Non-designation fine
€10M / 2%
whichever higher, of total worldwide annual turnover (Article 83(4)).
Time to appoint (us)
Days
registered with the supervisory authority within days of contract signature.
Full-time alternative
€60–120K+
in salary alone — before benefits, social charges, recruitment.
Our service
What's included in DPO as a Service.
What we deliver
- Named DPO with published contact details, registered with your supervisory authority
- All 11 statutory functions delivered and documented to GDPR requirements
- Regular reporting to your management body — quarterly minimum, ad hoc as required
- Direct availability to the supervisory authority per Article 38(4)
- Independent — no internal conflict of interest by design (Article 38(6))
- Bilingual delivery in English and French; coverage across France, Belgium, Luxembourg, Switzerland
- Backed by a team — no single point of failure on holidays, illness, or departure
- Onboarding and offboarding: registration with authority, transition from any prior DPO
Onboarding
Designed to start fast. Most engagements are fully active within two weeks.
Week 1
Scoping & contract
Confirm DPO mandate trigger, scope of processing, applicable supervisory authority. Engagement letter and Article 37(7) contact details.
Week 2
Registration & handover
Register DPO contact with supervisory authority. Take over from any prior internal or external DPO. Initial briefing with management.
Ongoing
Statutory function delivery
Monthly cadence of compliance monitoring, advisory, training oversight, supervisory authority contact, breach response readiness.
FAQ