DPO as a Service

Independent data protection expertise without the cost of a permanent DPO

Cheerful businesswoman meets with client

For organisations that need an independent Data Protection Officer (DPO), maintaining that expertise in-house isn’t always practical.

Data protection is an ongoing responsibility, and organisations need to understand how personal data is collected, used, stored and shared, while being able to demonstrate that appropriate measures are in place to comply with their obligations.

Risk Crew provides DPO as a Service, giving organisations access to experienced data protection expertise without the cost and commitment of employing a permanent DPO.

Do you need a Data Protection Officer?

Not every organisation is required to appoint a Data Protection Officer. Under the UK GDPR, a DPO is required where an organisation is a public authority or body, where its core activities involve regular and systematic monitoring of individuals on a large scale, or where its core activities involve large-scale processing of special categories of personal data or personal data relating to criminal convictions and offences.

These requirements apply to both controllers and processors, organisations that are not legally required to appoint a DPO can also choose to appoint one voluntarily. If they do, the DPO is subject to the same requirements and responsibilities.

If you’re unsure whether your organisation needs a DPO, Risk Crew can help you assess your requirements and determine the appropriate approach.

What is a Data Protection Officer?

A Data Protection Officer provides independent advice and oversight on an organisation’s data protection obligations; the role goes beyond maintaining privacy policies.

A DPO advises the organisation on its responsibilities, monitors compliance, supports Data Protection Impact Assessments, raises awareness, supports training and acts as a contact point for individuals and the Information Commissioner’s Office (ICO).

A DPO should be involved in data protection matters at an early stage and have sufficient access, resources and authority to perform their role effectively. The DPO does not take responsibility for the organisation’s compliance, accountability remains with the organisation itself. Instead, the DPO provides advice, monitoring and independent oversight to help the organisation meet its responsibilities and demonstrate compliance.

Why use an outsourced DPO?

Independent expertise Specialist knowledge without permanent recruitment.
Flexible support Scale support around your requirements.
Wider security expertise Access to Risk Crew's broader expertise.

Independence matters

Independence is a fundamental requirement of the DPO role. A DPO must be able to perform their tasks independently, must not be penalised for carrying them out and must report to the highest level of management.

Organisations must also provide adequate resources and ensure that other duties assigned to the DPO do not create a conflict of interest, this is particularly important when deciding who should perform the DPO role. An individual responsible for making decisions about how personal data is processed may not be able to independently monitor those same decisions as a DPO if this creates a conflict of interest.

An external DPO can provide a clear separation between operational decision-making and independent data protection oversight.

What does a DPO do?

Risk Crew’s DPO as a Service can provide ongoing support across the key responsibilities of the DPO role.

We provide advice on your data protection framework and help monitor whether policies, procedures and controls remain appropriate for your organisation.

We advise on DPIAs where processing is likely to result in a high risk to individuals and provide independent input throughout the assessment process.

We provide advice and support when your organisation receives requests relating to individual data protection rights, including Subject Access Requests.

When a potential personal data breach occurs, we can provide advice on the data protection implications, help assess the incident and support appropriate notification and communication.

We can review and advise on policies, procedures, records of processing activities and other documentation used to demonstrate accountability.

We help employees understand their responsibilities when handling personal data and support awareness and training activities.

We can provide advice on data protection considerations when working with processors, sub-processors and other third parties that handle personal data.

Your DPO can act as a contact point for the ICO and cooperate with the regulator on data protection matters where appropriate.

A DPO service built around your organisation
Your organisationYour dataYour risk
Size, structure and operating modelTypes and volume of personal dataLikelihood and impact of harm
Technology and systemsHow data is collected and usedSecurity and privacy exposure
Suppliers and third partiesWhere information is stored and transferredRegulatory and operational risk

Data protection by design, not after the fact

Privacy shouldn't be something you check once a project is finished. The earlier data protection is considered, the more opportunity there is to build appropriate safeguards into the way a product, service or process works.

01 Before
New project, technology, supplier or process

Identify
What personal data will be involved?

02 During
Assess the proposed processing

Evaluate
What are the risks to individuals?

03 Before launch
Put appropriate safeguards in place

Act
DPIA, controls, policies or other measures

DPO as a Service and information security

Data protection and information security are closely connected. Protecting personal data requires organisations to consider how information is accessed, stored, transferred and protected against unauthorised access, loss or compromise.

Risk Crew’s wider information security expertise allows our DPO service to work alongside security, governance and risk functions where data protection issues overlap with cyber security.

This can be particularly valuable when responding to personal data breaches, assessing suppliers, reviewing security controls or implementing new technology.

Why Risk Crew?

Risk Crew provides independent data protection expertise alongside wider information security, governance and risk capabilities.

Our DPO as a Service can complement your existing teams without requiring you to recruit and maintain a permanent DPO function internally.

We work with your organisation to understand its data protection requirements, provide independent advice and focus support where it can make the greatest difference.

The result is practical data protection oversight that is connected to the way your organisation operates.

FAQs

DPO as a Service provides an external Data Protection Officer under a service arrangement. It gives organisations access to specialist data protection expertise without requiring them to employ a permanent internal DPO.

A DPO is mandatory for certain organisations under the UK GDPR, including public authorities and organisations whose core activities involve certain types of large-scale monitoring or processing of sensitive personal data or criminal conviction and offence data. Organisations that are not required to appoint a DPO can also choose to appoint one voluntarily.

Yes. The ICO confirms that a DPO can be externally appointed. An external DPO must meet the same requirements around expertise, independence, resources and access as an internally appointed DPO.

A DPO advises the organisation on its data protection obligations, monitors compliance, provides advice on DPIAs, raises awareness and training, and acts as a contact point for individuals and the ICO.

A DPO must report to the highest level of management and have direct access to senior management and must be able to perform their tasks independently.

A Data Protection Impact Assessment (DPIA) is a process used to identify and address data protection risks associated with processing personal data, particularly where processing is likely to result in a high risk to individuals.

The cost depends on the size and complexity of the organisation, its processing activities and the level of DPO support required. Risk Crew can tailor the service around your requirements.

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Get independent DPO support

Whether you are required to appoint a DPO or want additional independent expertise, Risk Crew can provide practical support across your data protection responsibilities.