DPO as a Service

DPO as a service for SMBs: a qualified data protection officer, without the full-time hire.

Need a data protection officer, or not sure? We tell you, and can take on the role.

Does it apply to you?

Do you need a DPO?

Yes to any of the first three: GDPR requires one. The exact tests are in the section for your DPO or IT manager, below. The service is for organisations established in France, including the overseas regions.

  • Are you a public authority or public body?Then a data protection officer (DPO) is mandatory.
  • Is monitoring people at large scale core to your business?Behavioural advertising, location tracking, large-scale monitoring of staff. Then it is mandatory too.
  • Is handling sensitive data at large scale core to your business?Health, genetic, biometric or criminal data. Mandatory as well.
  • Do customers ask you to have one?Appointing a DPO voluntarily is often the simplest answer, and the CNIL encourages it.

Not in scope?

No DPO required? You still have GDPR duties.

Without a DPO, someone in your company still keeps the record of processing, answers people’s requests about their data and handles breaches. Our GDPR compliance work sets that up.

see GDPR compliance

What changes for you

An ongoing role with legal protections, not a one-off project.

A data protection officer advises your company on GDPR, checks that it is applied, and is the contact for the CNIL and for people asking about their data. The DPO reports to your top management and takes no instructions on how to carry out these tasks.

We provide that role as a service, for organisations established in France, metropolitan and overseas. Your consultant holds the EU GDPR Data Protection Officer certification. To stay independent, the DPO never decides why or how your data is processed, and we check for conflicts of interest before we start and every year.

Missing a DPO when one is required is a breach of GDPR in its own right. The fix is a quick answer on whether you need one, then a DPO in place in about three weeks.

What to do first

Confirm whether you need one, then appoint and register.

What we deliver

  • A clear answer: required, recommended or not needed
  • A named DPO, registered with the CNIL, with contact details published
  • Regular reports to your management, at least every quarter
  • Advice on impact assessments, breaches and people’s requests
  • Independence guarantees written into the engagement

Who does what

The DPO advises and checks. Your company keeps the decisions.

What your DPO does

  • Advise on GDPR and on impact assessments
  • Check compliance and report to management
  • Act as contact for the CNIL and for individuals
  • Train staff, or oversee their training

What stays with your company

  • Decide why and how data is processed
  • Apply the measures and answer requests on time
  • Notify breaches to the CNIL, with the DPO’s advice

Your company stays responsible for compliance; the DPO advises and monitors.

How it starts

Your first step: a free call to check whether you need one.

If you do, the service is a fixed monthly fee, set by your size and the data you handle, with no separate set-up fee.

Price
Fixed fee
Your time
A short call

Fixed quote after the free call.

book a free 25-minute consultation

For your IT manager, DPO or CFO

The DPO's tasks under GDPR — and what our service adds.
  1. 01

    Advise the controller, processor, and employees

    On obligations under GDPR and other data protection laws.

  2. 02

    Monitor compliance with GDPR

    Including responsibilities, awareness-raising, and training of staff involved in processing operations.

  3. 03

    DPIA advisory and oversight

    Provide advice on Data Protection Impact Assessments and monitor their performance.

  4. 04

    Be the supervisory authority contact

    Primary point of contact for the supervisory authority — the CNIL, for organisations established in France, including the DROM.

  5. 05

    Be the data-subject contact

    Designated contact for individuals exercising their data subject rights.

  6. 06

    Support the ROPA

    Develop and maintain Article 30 Records of Processing Activities.

  7. 07

    International transfers oversight

    Guide the organisation on lawful mechanisms for transferring personal data outside the EU/EEA.

  8. 08

    Advise on breach response

    Advice on breach assessment and on the controller's 72-hour notification to the authority and to individuals; oversight of the breach register.

  9. 09

    Deliver privacy training

    Or commission and oversee training for all staff handling personal data.

  10. 10

    Review privacy documentation

    Privacy notices, data processing agreements, consent mechanisms.

  11. 11

    Report to highest management

    Direct reporting line. Cannot receive instructions on the exercise of DPO tasks (Article 38).

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.

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)

    About 3 weeks

    from engagement to registration with the CNIL.

  • Full-time alternative

    A senior hire

    salary, social charges and recruitment — for a role many SMBs need only part-time.

Onboarding

Designed to start fast. Most engagements are fully active within about three weeks.

  1. Weeks 1–2

    Scoping & contract

    Confirm DPO mandate trigger, scope of processing, applicable supervisory authority. Engagement letter and Article 37(7) contact details.

  2. Week 3

    Registration & handover

    Register DPO contact with supervisory authority. Take over from any prior internal or external DPO. Initial briefing with management.

  3. Ongoing

    Statutory function delivery

    Monthly cadence of compliance monitoring, advisory, training oversight, supervisory authority contact, breach response readiness.

FAQ

What managers and IT teams ask us about the DPO role.

When exactly is a DPO mandatory?
Article 37(1) sets three triggers; any one is enough. (a) Public authorities and bodies, except courts acting in their judicial capacity. (b) Organisations whose core activities involve large-scale, regular and systematic monitoring of individuals, such as behavioural advertising, location tracking or employee monitoring at scale. (c) Organisations whose core activities involve large-scale processing of special-category or criminal data: health, genetic, biometric, religious or political opinions, sexual orientation, criminal convictions. Anyone may also designate a DPO voluntarily.
Can the same DPO serve multiple organisations?
Yes. Article 37(3) allows a group of undertakings or of public authorities to appoint a single DPO, provided the DPO is easily accessible from each establishment, and Article 37(6) allows the DPO to be a service provider. Cyber-Management's model serves several unrelated organisations independently, each with its own engagement, scope and registration with the authority.
Does the DPO need to be physically present in our country?
No. GDPR does not require physical presence, and Article 37(6) allows the DPO to be a service provider. The DPO must be easily accessible to data subjects, staff and the supervisory authority, which we ensure through dedicated contact channels, in French or English. The service covers organisations established in France, including the overseas regions (DROM), under the CNIL.
What qualifications does a DPO need?
Article 37(5) requires designation on the basis of professional qualities and expert knowledge of data protection law and practices. The consultant who acts as your DPO holds the EU GDPR Data Protection Officer certification (Advisera), alongside CISSP and PECB ISO/IEC 27001 Lead Auditor credentials, with direct experience of GDPR programmes, supervisory authority interactions and breach management.
How do we notify the supervisory authority?
Article 37(7) requires you to publish the DPO's contact details and communicate them to the supervisory authority. We handle this end to end during onboarding: the CNIL online form, the contact details in your privacy notice, and any sector-specific notification the authority requires.
What's the difference between a DPO and a privacy consultant?
A privacy consultant delivers defined projects (a GDPR audit, a privacy notice review, a DPIA) and steps back. A DPO holds an ongoing, legally defined position with specific GDPR obligations, independence protections and a direct line to the supervisory authority. The two are complementary: a DPO often commissions privacy consultants for specific work.
Can we replace an existing internal DPO with DPO as a Service?
Yes, with a managed transition: revoking the previous designation, updating the registration with the authority, keeping open matters moving (data subject requests, ongoing breaches, audits) and a structured briefing of the new DPO. We coordinate the whole handover so compliance stays continuous.