GDPR Articles 37–39 · Outsourced, named, filed

A senior privacy lawyer as your DPO — on record, on Slack, on call.

If you process personal data at scale, handle special categories, or operate in the public sector, GDPR requires a Data Protection Officer. We provide a named, independent, senior privacy lawyer — registered with the supervisory authority, embedded in your team, and backed by a bench of specialists.

Do I need a DPO?

Art. 37 is mandatory in three cases, plus one you'll feel in diligence.

Most teams discover the requirement during a DPA audit or a customer security review. We'd rather you discover it on a 10-minute call. Tick what's true.

Awaiting input

Tick what's true — we'll classify you.

A DPO is required when any of the three Art. 37(1) triggers apply. Outside those, it's often contractually required anyway — most enterprise-security reviews in 2024–25 ask for a named DPO regardless of legal obligation.

    Who your DPO actually is

    A real person. Named, credentialed, assigned.

    Not a rotating inbox. Not a junior paralegal. You get a senior privacy lawyer with sector-matched experience, filed with your lead DPA by name, reachable on Slack, backed by a team for peak load.

    LH

    Lena Hofmann · Senior Privacy Counsel

    Designated DPO · filed with BfDI · reference DPO-2026-00417

    ● ACTIVE · 14 CLIENTS
    Sector experience

    Healthtech, B2B SaaS, connected devices. Two Series C→IPO tours. Former in-house at a regulated European health platform.

    Languages

    Native German, working English & French. Files and responds to German, Austrian, and Swiss regulators in native.

    Availability model

    On Slack during CET business hours. 24h response on all client channels. Emergency hotline for breach events.

    Escalation bench

    Backed by 6 privacy counsels and external barristers at a magic-circle firm for litigation-grade matters.

    CIPP/E CIPM Qualified attorney · Germany 12 yrs privacy practice ISO 27001 lead auditor

    Sample assignment. Your DPO is matched by sector, regulatory geography, language, and existing customer workload.

    What your DPO does — and doesn't

    The statutory role, done well. No scope creep.

    In scope Art. 39

    • Advise on GDPR, UK GDPR, ePrivacy obligations, and national add-ons
    • Monitor compliance — audits, staff training, accountability
    • DPIA review, risk sign-off, prior consultation with the DPA (Art. 36)
    • Cooperate with and act as contact point for the supervisory authority
    • Data subject point of contact under Art. 38(4)
    • Report directly to the highest management level — written, board-ready
    • Incident & breach advisory, including Art. 33 / 34 notification drafts
    • Vendor DPAs, transfer mechanisms (SCCs + TIA), sub-processor register

    Out of scope By design

    • Determining purposes and means of processing — stays with your controllers. Independence is mandatory.
    • Litigating on your behalf — we brief external counsel and coordinate, but we don't act as barrister
    • Building your privacy engineering stack — we advise on requirements; your engineers build
    • Managing your security program — CISO-adjacent, but a distinct role (we can introduce a fractional CISO)
    • Contractual privacy negotiation with every customer — we give you the playbook and escalate the hard ones
    The boundary matters. Under Art. 38(6), the DPO must not face a conflict of interest with other tasks. We keep the role clean.
    How it works

    Designated, filed, operational — in two weeks.

    1. Scoping & matching

      90-minute call. We map your data processing, confirm Art. 37 applicability, and shortlist two DPOs matched to your sector and geography.

    2. DPO designated

      Mandate letter countersigned. Your DPO joins your Slack, gets read-only access to your privacy tooling, and completes the intake questionnaire.

    3. Filed & published

      We file the designation with your lead DPA, update your privacy policy with the Art. 37(7) contact details, and register the role in your Art. 30 records.

    4. 30-day baseline

      DPO delivers a compliance baseline — gaps, risks, priorities — to your highest management. Ongoing rhythm starts: weekly office hours, quarterly board report, annual audit.

    Privacy-policy snippet we provide
    // Required under GDPR Art. 37(7)
    
    Data Protection Officer
    Lena Hofmann
    c/o World Presence j.d.o.o.
    Ulica Brune Bušića 42, 10000 Zagreb
    
    Email: dpo@eupresence.com
    Ref:   ACME-DPO-2026
    
    // Filed with lead DPA:
    // DPO-2026-00417
    // Updated within 24h of any change.
    That filing is what regulators look for first. A named individual, a reachable contact, and a DPA reference on record.
    Proof

    Teams with a named DPO on file.

    From Series C healthtech to global adtech to regulated insurers — DPO designated, filed with the lead DPA, and embedded on your team within two weeks.

    "We'd been dodging the DPO question for 18 months. Having a senior counsel on Slack three days after signing was a step-change in how our team operates."
    Tom van der Meer CFO · Adtech, Amsterdam
    "DPA audit hit in month four. Our DPO handled correspondence in German, filed the response ahead of deadline, and closed it with no action."
    Rani Abad Head of Privacy · Insurtech
    "We compared an in-house hire vs this. The fully-loaded cost difference was 6× — for the same seniority and higher availability."
    Clara Bellini COO · B2B SaaS, Milan
    180+DPO designations filed
    27 + UKJurisdictional coverage
    < 2 weeksTime to operational
    0DPA findings, 2024–25
    Pricing

    Senior privacy counsel, at fractional cost.

    Designated
    $1,450/month
    Teams < 75 people · straightforward processing

    A named DPO on record, available monthly, with all the statutory duties covered and no scope creep.

    Included
    • Named DPO filed with lead DPA
    • Monthly office hour
    • Up to 4 DPIAs / year
    • Quarterly compliance check-in
    • Breach advisory during events
    Start on Designated →
    Most chosen
    Embedded
    $2,900/month
    Scaling teams · enterprise contracts

    Weekly office hours on Slack, unlimited DPIAs, board-ready reporting, vendor DPA review queue — plus GDPR Representative bundled.

    Everything in Designated, plus
    • Weekly office hours on Slack
    • Unlimited DPIAs & TIAs
    • Board-ready quarterly report
    • Vendor DPA review queue
    • GDPR Representative bundled
    Book a demo →
    Group DPO
    Custom
    Multi-entity · regulated · listed

    For multi-entity groups, regulated sectors, or listed companies needing a group-level DPO plus on-site presence.

    Everything in Embedded, plus
    • Multi-entity designation
    • Quarterly on-site days
    • Annual independent audit
    • 24/7 regulator hotline
    • Named deputy & custom MSA
    Talk to sales →
    Often purchased together

    The standard privacy foundations stack.

    Privacy Foundations Bundle

    Three products. One engagement. 15% off.

    DPO, external Representative, and the privacy UI your data subjects actually see. One onboarding, one counsel team, one invoice.

    You save $5,556 / yr
    BUNDLE TOTAL
    $3,084 / mo $2,621/ mo · 15% off Book a bundle call
    Common questions

    What GCs ask us first.

    Is an outsourced DPO actually allowed under GDPR?

    Yes, explicitly. Art. 37(6) permits the DPO to be "a staff member of the controller or processor or fulfil the tasks on the basis of a service contract." The EDPB guidance confirms this is a first-class option and specifically endorses it for SMEs and non-EU companies without local privacy staff.

    What's the difference between a DPO and an Art. 27 Representative?

    Different roles, often confused. A DPO (Art. 37–39) advises you on compliance — internal-facing. A Representative (Art. 27) is your legal EU-side contact for authorities and data subjects. If you have no EU establishment you may need both. We offer both, and bundle them.

    Does our DPO have access to confidential information?

    Yes — and they're bound by statutory confidentiality under Art. 38(5), enforceable in addition to our MSA. Your DPO signs your confidentiality policy, your code of conduct, and gets read-only access to the privacy tooling you choose.

    How does the DPO stay independent if we're paying them?

    The structure matters. The DPO reports to your highest management but receives no instructions on how to perform the role (Art. 38[3]). Our service contract replicates this: your DPO is engaged, paid, and can only be dismissed for cause. We maintain a firewall between billing and advisory.

    What happens if a regulator opens an investigation?

    Your DPO is the point of contact. They take the first correspondence, translate and coordinate with you, draft written responses, and — if things escalate — brief external counsel and sit with your GC. Breach-scale events trigger our 24/7 hotline and a full tabletop playbook.

    Can we switch DPOs mid-engagement?

    Yes, with 30 days' notice for cause, or at renewal for convenience. We file the change with your lead DPA, produce a handover dossier, and match you to a new DPO from our bench. Continuity is the whole point — the DPO you had never leaves without overlap.

    Your DPO, named on record this month.

    90-minute discovery call. A shortlist of two DPOs matched by sector. Designated, filed with the DPA, and published on your privacy policy in two weeks.