DPO as a Service: Complete Guide to Outsourced Data Protection Officers (2026)
February 21, 2026
Updated: February 22, 2026
27 min read
Data Protection
The GDPR mandates a Data Protection Officer for thousands of organisations — but hiring one full-time is expensive, slow, and often overkill. A qualified DPO in Western Europe commands a salary of €80,000–€150,000, and in the US the equivalent role (Senior Privacy Manager or Director of Privacy) runs $120,000–$200,000 plus benefits. Even finding qualified candidates takes months: the IAPP estimates a global shortage of hundreds of thousands of privacy professionals.
Enter DPO as a Service (DPOaaS) — the model where you outsource the Data Protection Officer function to an external specialist firm. It's faster to deploy, 60–80% cheaper than a full-time hire, gives you access to a team rather than a single person, and satisfies the GDPR's requirements just as effectively. Companies from Silicon Valley startups to London fintechs are choosing this model, and EU-based providers — particularly in cost-effective markets like Croatia — are delivering the expertise at a fraction of Western European rates.
This guide covers everything: who needs a DPO, how outsourcing works, what it costs, how to evaluate providers, and why the model is becoming the default for organisations that need GDPR compliance without the overhead of a full-time executive.
Quick Reference
Details
What is DPO as a Service?
Outsourcing the GDPR-mandated Data Protection Officer role to an external specialist firm
Other names
DPOaaS, external DPO, outsourced DPO, virtual DPO
Who must appoint a DPO
Public authorities; organisations whose core activities involve large-scale systematic monitoring or large-scale processing of special category data (Articles 37-39 GDPR)
DPO as a Service is explicitly permitted by GDPR Article 37(6), which states the DPO "may be a staff member or fulfil the tasks on the basis of a service contract"
An external DPO must meet the as an internal one — there's no reduced standard
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same independence, expertise, and accessibility requirements
Outsourced DPO costs typically range from €500 to €5,000 per month, saving 60–80% compared to a full-time hire when total compensation is considered
The DPOaaS model gives you access to a team of specialists rather than a single person, providing broader expertise and continuity
Your external DPO should have expert knowledge of data protection law and practices (Article 37(5)), with demonstrable experience in your industry and relevant certifications (CIPP/E, CIPM, CDPO)
Croatia-based DPO providers offer a compelling value proposition: full EU credentials, AZOP (Croatian DPA) familiarity, multilingual teams, and 40-60% lower rates than Irish, German, or Dutch equivalents
The DPO must remain independent — even as an external service, they cannot receive instructions regarding the exercise of their tasks (Article 38(3))
Start with a clear service level agreement defining tasks, availability, escalation procedures, and reporting cadence
DPO as a Service (DPOaaS) is a model where an organisation outsources the role of Data Protection Officer to an external firm rather than appointing an in-house employee. The external provider designates a named DPO (and typically a backup) who performs all the functions required by GDPR Articles 37-39, supported by a team of data protection specialists.
The DPO is formally designated as the organisation's Data Protection Officer, registered with the relevant supervisory authority, and listed in the privacy notice. To regulators, data subjects, and business partners, the external DPO functions identically to an internal one.
How the model typically works:
Named DPO: A senior data protection professional is designated as your DPO of record
Support team: Analysts and specialists handle operational tasks (DSARs, DPIAs, training materials)
Regular engagement: Monthly or bi-weekly meetings, ongoing availability for urgent matters
Defined hours: Most engagements include a monthly hour allocation (10–40 hours typical)
Scalable capacity: Additional hours or project work available on demand
Annual review: Formal assessment of the DPO programme's effectiveness
The model has existed since GDPR came into force in 2018, but adoption has accelerated dramatically since 2023 as enforcement intensified and the DPO talent shortage deepened.
Who Must Appoint a DPO Under GDPR?
Article 37(1) of the GDPR requires a DPO when any of the following conditions apply:
Mandatory DPO appointment criteria
Criterion
Article
Examples
Public authority or body
37(1)(a)
Government agencies, public hospitals, state universities, municipalities
Core activities require regular and systematic monitoring of data subjects on a large scale
Core activities involve large-scale processing of special category data or criminal conviction data
37(1)(c)
Hospitals, genetic testing companies, criminal background check services, political organisations
What counts as "core activities"?
The EDPB (formerly Article 29 Working Party) clarified that "core activities" are the key operations necessary to achieve the controller's or processor's objectives — not just ancillary processing like HR or IT support.
Company
Core Activity
DPO Required?
Hospital
Treating patients (processing health data)
Yes — large-scale special category data
Marketing analytics firm
Profiling consumers
Yes — regular and systematic monitoring at scale
Small law firm
Providing legal services
Usually no — processing is not large-scale
Online retailer with 100K EU customers
Selling products
Possibly — depends on scale of monitoring (analytics, profiling)
HR software provider
Processing employee data for clients
Yes — systematic monitoring, processing on behalf of many organisations
SaaS with 50 EU users
Providing software
Probably no — not large-scale (but may voluntarily appoint)
National laws may expand the requirement
Many EU member states have added DPO requirements beyond the GDPR baseline:
Germany: DPO required if 20+ employees regularly process personal data
France: DPO recommended for any systematic health data processing
Croatia: AZOP recommends DPO appointment for any significant processing of Croatian residents' data, even below the GDPR thresholds
Austria: DPO strongly recommended for large-scale video surveillance (DPIA also required)
Even if GDPR doesn't mandate it, voluntarily appointing a DPO (internal or external) is increasingly seen as best practice and is positively viewed by regulators during investigations.
The Legal Basis for External DPOs
Article 37(6) provides clear authorisation:
"The data protection officer may be a staff member of the controller or processor, or fulfil the tasks on the basis of a service contract."
This means external DPOs are not a workaround or a lesser option — they're explicitly contemplated and authorised by the GDPR. The EDPB has confirmed this in its guidelines on DPOs (WP243 rev.01), noting that:
A group of undertakings may appoint a single external DPO (Article 37(2))
The external DPO must be accessible to each establishment and supervisory authority
The service contract should contain appropriate terms to ensure GDPR compliance
The external DPO is protected by the same provisions against dismissal/penalty as an internal DPO
External DPO requirements checklist
Requirement
GDPR Article
Applies to External DPO?
Expert knowledge of data protection law and practices
37(5)
Yes
Ability selected on basis of professional qualities
37(5)
Yes
No conflict of interest with other tasks
38(6)
Yes
No instructions regarding exercise of tasks
38(3)
Yes
Not penalised for performing DPO tasks
38(3)
Yes
Report to highest level of management
38(3)
Yes
Provided with necessary resources
38(2)
Yes — through the service contract
Bound by secrecy/confidentiality
38(5)
Yes
Contact details communicated to DPA
37(7)
Yes
Contact details published in privacy notice
13(1)(b), 14(1)(b)
Yes
DPO as a Service vs. Internal DPO: Complete Comparison
Dimension
External DPO (DPOaaS)
Internal DPO
Cost
€6,000–€60,000/year
€80,000–€200,000/year (salary + benefits)
Time to deploy
2–4 weeks
3–6 months (recruitment + onboarding)
Expertise breadth
Team of specialists with multi-industry experience
Single individual's knowledge
Continuity
Provider ensures backup/succession
Risk if employee leaves
Independence
Naturally more independent (separate entity)
Requires organisational safeguards
Organisational knowledge
Requires onboarding; builds over time
Deep institutional knowledge
Availability
Defined hours with on-demand surge
Full-time presence
Scalability
Easy to scale up/down
Fixed cost regardless of workload
Regulatory experience
Cross-client, cross-jurisdiction
Single organisation
DPA interaction
Experience dealing with multiple DPAs
May have limited DPA experience
Cultural fit
May take time to understand company culture
Embedded in the organisation
Conflict of interest
Clear separation (though provider must not serve conflicting clients)
Other duties may create conflicts
Legal protection
Contract terms protect the DPO function
Employment law protections
When DPOaaS makes more sense
Budget-conscious organisations — especially SMEs and startups
Companies in multiple EU jurisdictions — need multi-country expertise
Organisations with limited privacy workload — don't need a full-time person
Companies scaling into the EU — need to move fast
Organisations wanting independence — external status enhances DPO independence
Private equity portfolio companies — standardised DPO across multiple entities
When an internal DPO makes more sense
Large enterprises with complex, daily privacy operations
Organisations processing high-risk data continuously (hospitals, intelligence agencies)
Companies where the DPO needs to attend daily meetings and be constantly embedded
Organisations with budget for a dedicated senior hire
What Does an Outsourced DPO Actually Do?
Core DPO tasks (Article 39)
Task
What It Means in Practice
Inform and advise the controller/processor and employees
Regular privacy guidance, training sessions, policy review, responding to internal questions
Monitor compliance with GDPR and other data protection laws
Audits, gap assessments, compliance reviews, tracking regulatory changes
Advise on DPIAs (Data Protection Impact Assessments)
Reviewing processing activities, conducting DPIAs for high-risk processing, recommending mitigations
Cooperate with the supervisory authority
Handling DPA inquiries, facilitating inspections, attending meetings with regulators
Act as the contact point for the DPA
Available for the DPA to contact on any matter related to processing
Have due regard to risk
Prioritising oversight based on the nature, scope, context, and purposes of processing
Typical monthly deliverables from a DPOaaS provider
Deliverable
Frequency
Monthly compliance status report
Monthly
DPIA reviews for new processing activities
As needed
Data Subject Access Request (DSAR) management
Ongoing
Breach notification support
As needed (with SLA)
Privacy policy and notice reviews
Quarterly or as needed
Staff privacy awareness training
Quarterly or semi-annually
Record of processing activities (ROPA) maintenance
Ongoing
Regulatory update briefings
Monthly
Annual privacy audit/assessment
Annually
DPA correspondence management
As needed
DPO as a Service Cost: Pricing Models and Benchmarks
Pricing models
Model
Range
Best For
Monthly retainer
€500–€5,000/month
Most organisations — predictable costs
Tiered packages
Basic (€500–€1,000), Standard (€1,000–€2,500), Premium (€2,500–€5,000)
Organisations wanting defined service levels
Hourly rate
€100–€350/hour
Low-volume, project-based needs
Annual fixed fee
€6,000–€60,000/year
Organisations wanting annual budget certainty
Per-entity pricing
Additional €200–€1,000/entity/month
Groups of undertakings or PE portfolio companies
What drives the price?
Factor
Impact
Processing complexity
More complex data flows = more DPO oversight needed
Data subject volume
Higher volumes = more DSARs, more risk, more work
Special category data
Health, biometric, genetic data requires more expertise
Industries under active DPA scrutiny need more engagement
Provider location
Western EU providers charge 2-3x Croatian/Eastern EU providers
Included services
Training, DPIA support, ROPA management may be extra or bundled
Cost comparison by provider location
Provider Location
Monthly Cost Range
Annual Cost Range
Notes
Ireland
€2,000–€7,000
€24,000–€84,000
Highest rates, strong DPC proximity
Germany
€1,500–€6,000
€18,000–€72,000
Multiple DPA expertise needed
Netherlands
€1,500–€5,000
€18,000–€60,000
Good English, mid-range pricing
France
€1,500–€5,500
€18,000–€66,000
CNIL expertise, French language skill
Croatia
€500–€2,500
€6,000–€30,000
40-60% savings, full EU credentials
Poland
€600–€2,500
€7,200–€30,000
Cost-effective, growing market
Spain
€800–€3,000
€9,600–€36,000
Mid-range, AEPD expertise
Sample pricing scenarios
Organisation Profile
Western EU DPOaaS
Croatia-Based DPOaaS
Savings
SaaS startup, 200 EU users, standard processing
€1,500–€2,500/mo
€500–€1,000/mo
60-70%
Mid-market e-commerce, 50K EU customers
€2,500–€4,000/mo
€1,000–€2,000/mo
50-60%
Healthtech company, processing patient data
€3,500–€5,500/mo
€1,500–€2,500/mo
50-55%
PE portfolio (5 entities)
€8,000–€15,000/mo
€3,000–€6,000/mo
55-65%
Financial services, regulated data
€3,000–€6,000/mo
€1,200–€2,500/mo
55-60%
Why EU-Based DPO Providers (and Why Croatia)
Why your DPO should be EU-based
While GDPR doesn't explicitly require the DPO to be located in the EU, there are strong practical and strategic reasons to choose an EU-based provider:
DPA interaction: Supervisory authorities can contact the DPO directly — EU-based providers operate in the same legal and timezone context
Regulatory familiarity: EU-based DPOs understand the regulatory culture and enforcement patterns firsthand
Language: They can communicate with DPAs in official EU languages
Credibility: EU-based DPOs signal serious commitment to data protection to regulators and business partners
No international transfer issues: DPO communications about your processing don't create additional transfer complications
Why Croatia specifically
1. Full EU and eurozone membership
Croatia has been an EU member since 2013 and joined the eurozone in 2023. A DPO based in Croatia has identical regulatory standing to one in any other member state. This is not a "budget alternative" — it's a strategic choice with full legal equivalence.
2. AZOP expertise
Croatia's DPA — the Agencija za zaštitu osobnih podataka (AZOP) — is an active participant in the EDPB's consistency mechanism. Croatian DPO providers work directly with AZOP, giving them practical experience with DPA interactions that translates to effective advocacy on your behalf with any EU supervisory authority.
3. Multilingual, educated workforce
Croatian compliance professionals typically speak English fluently, with many also proficient in German, Italian, or French. Croatian universities offer specialised programmes in EU law, data protection, and regulatory compliance. The professional talent pool is deep relative to the country's size.
4. Cost-effective without quality compromise
The 40-60% cost advantage comes from Croatia's lower operating costs — not from any compromise on expertise. Croatian DPO providers serve clients across the EU and hold the same certifications (CIPP/E, CIPM, ISO 27001 Lead Auditor) as their Western European counterparts.
5. Growing compliance ecosystem
Croatia has developed a robust ecosystem of compliance and data protection firms, many serving international clients. This concentration of expertise drives quality through competition and knowledge sharing.
6. Central European timezone
CET/CEST alignment means Croatian providers share business hours with all of continental Europe and have comfortable overlap with UK and US East Coast clients.
How to Evaluate DPO as a Service Providers
Must-have criteria
1. Demonstrated data protection expertise
Relevant certifications: CIPP/E, CIPM, CDPO, ISO 27001 Lead Auditor
Verifiable experience as DPO for similar organisations
Understanding of your industry's specific data protection challenges
Track record of DPA interactions and compliance audits
2. Independence and conflict management
Clear policies on avoiding conflicts of interest between clients
The provider shouldn't serve your direct competitors simultaneously without safeguards
Documented procedures for maintaining DPO independence
3. Named DPO with backup
You should know who your designated DPO is (not just "our team")
A named backup DPO must be available for continuity
Both should have appropriate qualifications
4. Availability and responsiveness
Defined SLAs for response times (e.g., 4-hour response for breaches)
Monthly meeting cadence
On-demand availability for urgent matters
Clear escalation procedures
5. Multi-jurisdictional capability
If you process data across multiple EU countries, your DPO provider should understand the relevant national implementations
Experience with multiple DPAs is a significant advantage
Evaluation scorecard
Criterion
Weight
Questions to Ask
Expertise
30%
Certifications? Years of DPO experience? Industry specialisations? DPA interaction examples?
Service model
20%
Hours included? Scope of services? What's extra? How are DPIAs handled?
Responsiveness
15%
SLA for breach response? Regular meeting cadence? Emergency availability?
Cost
15%
Total cost including all services? Hidden fees? Annual increase cap?
Independence
10%
Conflict of interest policies? Other clients in your sector?
References
10%
Can they provide client references? Case studies? DPA endorsements?
Red flags
Red Flag
Why It Matters
No named DPO — "our team will serve as your DPO"
GDPR requires a designated individual, not a generic team
No DPA interaction experience
Your DPO needs to be effective when regulators come calling
Extremely low fees (under €200/month)
Suggests insufficient expertise or time commitment
No independence safeguards
The provider may also serve conflicting clients
DPO also serves as your processor
Major conflict of interest — the DPO would be monitoring their own company
No DPIA or ROPA capability
Core DPO functions that can't be omitted
Structuring an External DPO Engagement
The service agreement essentials
Your DPOaaS contract should cover:
1. Scope of services
Exactly which DPO tasks (Article 39) are included
Which entities are covered (parent company, subsidiaries, specific business units)
Geographic scope (which EU/EEA countries)
Hours included and overflow rates
2. Named personnel
Designated DPO (with qualifications)
Deputy/backup DPO
Support team members and their roles
3. Service levels
Response time for DPA inquiries (recommend: 24 hours)
Response time for data breach incidents (recommend: 4 hours)
DSAR processing support timeline
Regular reporting cadence (monthly recommended)
Annual compliance review
4. Independence provisions
Confirmation that the DPO will not receive instructions on exercise of tasks
Conflict of interest management procedures
Direct reporting line to senior management
Protection from termination for performing DPO duties
5. Data protection
How the DPO provider handles data it receives in performing its role
Confidentiality obligations
Sub-processor restrictions
Data retention and deletion after engagement ends
Onboarding your external DPO
A good DPOaaS provider will follow a structured onboarding process:
Phase
Activities
Timeline
Discovery
Review current processing activities, policies, ROPA, DPIAs, previous audits
Formally register the DPO with relevant supervisory authority(ies)
Week 2-3
Documentation
Update privacy notices, internal policies, ROPA with DPO details
Week 3-4
Communication
Announce DPO appointment internally and externally
Week 4
Steady state
Ongoing DPO services begin with first monthly report
Month 2
Independence Requirements: What External DPOs Must Know
DPO independence is one of the most misunderstood aspects of GDPR. Article 38(3) states:
"The controller and processor shall ensure that the data protection officer does not receive any instructions regarding the exercise of those tasks."
What independence means in practice
Allowed
Not Allowed
Defining priorities collaboratively
Instructing the DPO to approve a specific processing activity
Requesting the DPO's opinion on a project
Overriding the DPO's assessment of a DPIA
Setting meeting cadence and reporting formats
Telling the DPO to delay a breach notification
Providing business context for DPO assessments
Penalising the DPO for recommending against a project
Asking the DPO to prioritise certain assessments
Directing the DPO not to report a compliance concern
External DPO independence advantages
External DPOs often have a natural independence advantage over internal DPOs:
Financial independence: Their income doesn't depend on a single client's satisfaction
Organisational distance: They're not embedded in the company culture or hierarchy
Multiple-client perspective: Experience across organisations gives them clearer benchmarks
Easier to challenge decisions: Less social pressure than an employee disagreeing with their CEO
Contractual protection: The service agreement can codify independence provisions more robustly than employment contracts
DPO as a Service for Specific Industries
Technology and SaaS
Key challenges: High data volumes, complex international transfers, rapid product development, AI/ML processing
DPO focus areas: Privacy by design reviews, DPIA for new features, cross-border transfer mechanisms, AI Act intersection
Typical engagement: Standard tier (€1,000–€2,500/month) with additional project hours for product launches
Healthcare and biotech
Key challenges: Special category data (health, genetic), clinical trials, European Health Data Space (EHDS) compliance
DPO focus areas: Health data governance, clinical trial data protection, patient consent management, genetic data requirements
Typical engagement: Premium tier (€2,000–€5,000/month) due to special category data complexity
Financial services
Key challenges: Intersection of GDPR, DORA, PSD2, AML/KYC regulations; high-volume transactional data
DPO focus areas: Regulatory overlap management, data retention (AML vs. GDPR), profiling and automated decisions, third-party risk
Typical engagement: Premium tier with financial services specialisation
E-commerce and retail
Key challenges: Large customer databases, marketing consent, cookie compliance, cross-border sales
DPO focus areas: Consent management, marketing data processing, loyalty programme compliance, ePrivacy requirements
Typical engagement: Standard tier, scaling with customer base size
Professional services
Key challenges: Client confidentiality, legal privilege considerations, cross-border matters
DPO focus areas: Client data governance, information barriers, international transfer mechanisms
Typical engagement: Basic to standard tier, depending on firm size
Common Mistakes When Outsourcing the DPO Function
1. Choosing on price alone
The cheapest DPOaaS provider is rarely the best value. A DPO who can't effectively handle a DPA inquiry or misses a DPIA requirement exposes you to fines that dwarf any savings.
2. Not ensuring genuine independence
Some organisations treat their external DPO like a vendor they can direct. The DPO must remain independent in their assessments — even when the conclusions are inconvenient.
3. Insufficient hours allocation
Under-resourcing the DPO engagement means compliance gaps go undetected. If your provider is consistently over their hour allocation, you need a higher tier — not less oversight.
4. No onboarding process
Bringing on an external DPO without proper onboarding means they'll be ineffective for months. Invest in a thorough discovery phase.
5. Treating the DPO as a checkbox
The DPO isn't there to make a compliance certificate look complete. They should be actively engaged in your processing decisions, consulted before new projects launch, and taken seriously when they flag concerns.
6. Not providing access
An external DPO needs access to your systems, processes, and personnel. Restricting access undermines their ability to monitor compliance effectively.
7. Confusing DPO with GDPR representative
If you're a non-EU company, you may need both a DPO and an Article 27 representative. They're different roles with different requirements, though the same provider can often deliver both.
When to Transition from External to Internal DPO
DPOaaS isn't always permanent. Consider transitioning to an internal DPO when:
Organisation growing rapidly in EU data processing
Scale demands full-time attention
Cultural shift — privacy is becoming core to your product/brand
Internal champion more effective than external advisor
Best practice: Many organisations run a hybrid model — hiring an internal privacy manager while retaining the external DPOaaS provider as the formal DPO for independence and breadth of expertise. Croatian providers are particularly well-suited to this model, offering ongoing strategic DPO oversight while your internal team handles day-to-day operations.
Frequently Asked Questions
Is DPO as a Service really GDPR-compliant?
Yes. Article 37(6) explicitly states that the DPO "may be a staff member of the controller or processor, or fulfil the tasks on the basis of a service contract." The EDPB guidelines confirm external DPOs are fully compliant, provided they meet the same expertise, independence, and accessibility standards as internal DPOs.
How many hours per month does an external DPO need?
It depends on your processing complexity and volume. Typical ranges:
Small organisations with simple processing: 5–10 hours/month
Mid-market companies with moderate complexity: 15–25 hours/month
Larger organisations or those processing special categories: 25–40+ hours/month
Can one external DPO serve multiple organisations?
Yes. Article 37(3) explicitly allows a single DPO for a group of undertakings, and in practice, DPOaaS providers serve multiple clients. The provider must manage conflicts of interest (e.g., not serving direct competitors with conflicting interests) and ensure adequate resources for each client.
Does the external DPO need to be in the same country as my company?
No. GDPR doesn't specify a location requirement for the DPO. However, an EU-based DPO is strongly recommended for practical reasons: timezone alignment, DPA familiarity, language capability, and credibility. Croatia-based providers offer these advantages at competitive rates.
What happens if my external DPO identifies a serious compliance issue?
The DPO reports the issue to your senior management (Article 38(3) — DPO "shall directly report to the highest management level"). You're then responsible for addressing it. If you don't, the DPO should document their recommendation and your response. The DPO is not personally liable for your non-compliance, but they must act with professional integrity.
Can my DPO provider also provide other compliance services?
Yes, but with safeguards. The DPO provider can offer additional services (compliance consulting, training, audit support), provided these don't create conflicts of interest with the DPO function. For example, a provider shouldn't simultaneously serve as your DPO and as a processor handling your data. Combining DPO services with Article 27 representative services or general compliance advisory is generally acceptable and common.
How do I formally designate an external DPO?
Execute a service contract with the DPO provider
Issue an internal appointment letter naming the external DPO
Communicate the DPO's contact details to the relevant supervisory authority (Article 37(7))
Update your privacy notice to include the DPO's contact details
Announce the appointment internally so employees know who to contact
What certifications should my external DPO have?
While GDPR doesn't mandate specific certifications, reputable providers should hold:
CIPP/E (Certified Information Privacy Professional/Europe) — IAPP
CIPM (Certified Information Privacy Manager) — IAPP
CDPO (Certified Data Protection Officer) — ECPC Board
ISO 27001 Lead Auditor — for security-related assessments
Legal qualifications in EU data protection law are a strong bonus
Looking for an EU-based DPO as a Service? Vision Compliance provides external DPO services from Croatia, combining deep GDPR expertise with 40-60% cost savings compared to Western EU providers. Schedule a consultation to learn how we can serve as your designated Data Protection Officer.
Ivana Ludiga·Associate·mag. iur.
Ivana Ludiga, mag. iur., is an Associate at Vision Compliance focused on data protection, GDPR implementation, and regulatory advisory. She supports compliance projects for organizations across healthcare, financial services, and technology sectors.
