DPO as a Service (Outsourced DPO)
Experienced outsourced data protection officer for UK businesses that need accountability, ICO-ready oversight, and ongoing GDPR compliance without a permanent hire.
What This Service Solves
Some UK organisations must appoint a DPO under UK GDPR Article 37. Others choose to. Either way, many don't have enough DPO work to justify a permanent, full-time role. Not sure which applies to you? See when your business needs a DPO.
Our DPO as a Service gives you an experienced DPO on a fractional basis, with their contact details published and notified to the ICO as Article 37(7) requires. Your DPO independently advises and monitors your compliance, while your organisation stays responsible for meeting UK GDPR, as the ICO's guidance on data protection officers sets out.
Why Fractional DPO Oversight Avoids Conflicts of Interest
Under UK GDPR Article 38(6), a DPO may perform other tasks, but the controller must ensure those tasks do not result in a conflict of interest. An in-house DPO who also holds an operational or C-suite role (such as CTO, Head of Marketing, or CEO) cannot independently evaluate their own processing designs. An outsourced DPO provides senior, conflict-free oversight that satisfies Article 38(3) independence standards.
When an Outsourced DPO Makes Sense
Key operational triggers and compliance checkpoints where appointing an outsourced Data Protection Officer is essential:
GDPR Requires a DPO
Statutory obligation under UK GDPR Article 37 for public bodies, systematic monitoring, or large-scale special category data.
Lack of In-House Privacy Leadership
Missing dedicated senior privacy expertise to guide product development, data handling, and engineering teams.
Need Regulator-Ready Oversight
Preparing your organisation for ICO inspections, audits, and formal regulatory inquiries with defensible documentation.
Need Continuity and Accountability
Establishing persistent privacy governance without the high fixed cost or overhead of a full-time executive hire.
Vendor or Investor Due Diligence
Vendor or investor due diligence asks for a named, qualified DPO.
ICO Contact Details Notification
You need to notify the ICO of your DPO's contact details
What We Provide
Comprehensive fractional DPO capabilities tailored to your operational scale:
Acting DPO Appointment
An acting DPO, with support for publishing their contact details and notifying the ICO
Ongoing Compliance Oversight
Ongoing GDPR and UK GDPR compliance oversight
DSAR Intake & Management
DSAR escalation support, with full response management available at extra cost
Regulator & ICO Correspondence
Incident and breach escalation support
DPIA & Risk Governance Advice
Regulator and ICO correspondence handling
Reporting & Programme Review
Advice on DPIAs, processing risk, and data governance
Ongoing Oversight via Your Compliance Dashboard
Your dashboard provides a living view of your compliance posture. Your named DPO is available during UK business hours for advice, escalations, and regulator correspondence. Urgent or out-of-hours support is charged separately.
Compliance visibility: Audits, risks, and actions
Compliance visibility: Audits, risks, and actions
Structured inputs: Ongoing questions and evidence
Structured inputs: Ongoing questions and evidence
Accountability: Clear ownership and audit trail
Accountability: Clear ownership and audit trail
How We Work
Here is how we guide your organisation from initial risk profiling to ongoing DPO oversight:
Step 1: Understand your organisation and risk profile
We review your existing data processing activities, identify Article 37 triggers, and agree the scope and format of the DPO engagement. If a DPO isn't legally required, we tell you, so you can decide whether a voluntary appointment still makes sense.
Step 2: Establish the governance and oversight model
We agree how your DPO reports to your highest management level, how issues get escalated, and which teams they work with day to day. We also check the arrangement meets the Article 38 independence rules, so your DPO can advise without taking instructions on how to do the job.
Step 3: Provide ongoing DPO support
Your named DPO monitors compliance, advises on new projects, and answers questions from staff and data subjects. You get regular reporting on open risks, actions, and progress.
Step 4: Support audits, DPIAs, DSARs, and regulators
When a DPIA, subject access request, audit, or ICO query comes in, your DPO advises on and supports the response. We document key advice, decisions, and agreed actions with your teams, so you have a clear record if a regulator asks how you reached them.
What Makes This Defensible
Our DPO service is built to withstand rigorous regulatory scrutiny and partner due diligence.
Senior, independent oversight
Objective, uncompromised privacy guidance reported directly to board level.
Separation of Advice & Accountability
Clear separation meeting Article 38 independence standards without operational conflict.
Documented decisions and rationale
Written evidence trail and signed justifications supporting every processing decision.
Regulator-ready evidence
Complete audit records formatted to satisfy ICO inspections and partner due diligence.
Tom S.
Medical Practice
"Improved control over sensitive medical data"
"Practical guidance on access controls and data protection. Helped define structured access policies and introduced tokenisation for patient identifiers used in analytics."
Sarah S.
Retail, Enterprise
"Reliable partner for telecom data protection"
"Quickly understood telecom data complexity; helped classify sensitive datasets and apply protection measures for subscriber, usage, and billing data."
Pauliina H.
Entertainment, Enterprise
"Effective support for securing customer data"
"Identified where sensitive data lived and applied tokenization and anonymization strategies in a complex telecom environment."
Jordan R.
Computer Networking
"Practical approach to safeguarding e commerce"
"Helped protect PII, payment data, and order histories with tokenization and anonymization; advised on GDPR compliance for international operations."
Charmaine S.
Int. Trade & Development
"Systematic Approach Enhances Data Security"
"Methodical approach through discovery, planning, and implementation; implemented Microsoft Purview for a scalable compliance framework."
Kateryna H.
IT and Services
"Practical approach to protecting sensitive Data"
"Structured data discovery and classification combining technical analysis with finance data privacy expertise; strong masking and tokenization policies."
Snow D.
Market Research
"Practical expertise for telecom information"
"Introduced tokenization and controlled access strategies for subscriber data while still supporting analytics and reporting."
Laura H.
Hospital & Health Care
"Valuable expertise in healthcare protection"
"Strong expertise in healthcare data security; introduced anonymization techniques for safely using patient data in research and reporting."
Frequently Asked Questions
Common questions regarding outsourced Data Protection Officer services and ICO compliance requirements.
Yes. UK GDPR Article 37(6) explicitly allows the DPO to be a staff member or to fulfill the tasks on the basis of a service contract. You can publish their contact details and notify the ICO of your outsourced DPO.
A DPO is mandatory if you are a public authority, if your core activities require large-scale systematic monitoring of individuals, or if you process special category data on a large scale. To check whether these criteria apply to your organisation, view our detailed guide on when your business needs a DPO.
Under Article 38(6), a DPO cannot hold an operational role that determines the purposes and means of processing (such as CTO, CEO, or Head of Marketing). As an independent external partner, KEWDATA provides conflict-free oversight.
Your named DPO is available during UK business hours for urgent escalations, DSAR triage, and regulator correspondence, ensuring statutory deadlines (like the 1-month DSAR window) are strictly met.
Our DPOs hold industry-standard IAPP certifications including CIPP/E (Certified Information Privacy Professional/Europe) and CIPM (Certified Information Privacy Manager), backed by real ICO interaction experience.
Discuss DPO as a Service
We'll tell you honestly whether our outsourced DPO service is the right fit for your UK business and whether a DPO is legally required under Article 37.
Book a Free DPO Scoping Call