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SERVICE PRACTICE · DATA PROTECTION & GDPR

External DPO and full GDPR programme.

We act as your external Data Protection Officer, build the full GDPR programme, and deliver audit-ready documentation. DSAR handling, breach response, DPIA, vendor DPAs and supervisory liaison included.

DPO.DESK · LAST 30 DAYS● LIVE
Data subject requests handledavg 9 d cycle128
DPIAs reviewed / signed17
Vendor DPAs negotiated34
Article 33 incidents triaged1 notified4
Cross-border transfer assessments11
Records of Processing entries kept current420
TRUSTED BY 300+ EU ORGANISATIONS
RocheSiemensAstraZenecaInditexKončarOrbicoFortenova
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One business day reply. Clear next steps and indicative pricing.

1 BUSINESS DAY REPLYNDA ON REQUESTNO OBLIGATION
01 / GDPR IN 60 SECONDS

GDPR overview.

WHAT

EU regulation since 2018 governing personal data.

Sets the rules for how organisations collect, store, use and share personal data of people in the EU.

WHO

Anyone processing EU personal data, anywhere.

Applies regardless of where the organisation is headquartered. Sole proprietors to multinationals. Same rulebook.

WHY NOW

Most-fined regulation in the EU. €5.9B issued.

Fines up to €20M or 4% of global turnover. Enforcement is cross-border, coordinated, and accelerating.

TIER 1 · PROCEDURAL
Up to €10M or 2% turnover
Records, security measures, breach notification, DPIA failures.
TIER 2 · SUBSTANTIVE
Up to €20M or 4% turnover
Lawful basis, data subject rights, international transfers, principles.
02 / ARTICLES IN SCOPE

Articles in scope.

DATA SUBJECT RIGHTS
Art. 15Right of accessConfirmation, copy, processing context.
Art. 16-17Rectification and erasureCorrect or delete. Right to be forgotten.
Art. 20Data portabilityStructured, machine-readable export.
Art. 21-22Objection and automated decisionsOpt-out of profiling. Human review of AI decisions.
CORE OBLIGATIONS
Art. 30Records of processingInventory of activities, purposes, recipients, retention.
Art. 32Security of processingTechnical and organisational measures, tested.
Art. 33Breach notification72 hours to the supervisory authority.
Art. 35DPIA for high-risk processingPre-deployment assessment. Residual risk sign-off.
Art. 37-39Data Protection OfficerAppointed, named, independent, reachable.
03 / HOW TO ENGAGE

Engagement models.

DPOMOST POPULAR

DPO-as-a-Service

Outsourced Data Protection Officer named to the supervisory authority. We run your privacy programme end-to-end on a monthly retainer.

  • →Named DPO of record
  • →Monthly steering review
  • →DSAR and breach response
  • →Annual programme report
PROG12-16 WK

GDPR Programme Implementation

Fixed-scope, fixed-fee build of a complete programme. Policies, RoPA, DPIAs, vendor stack, training, controls.

  • →Full policy stack
  • →Records of Processing
  • →DPIA library
  • →Trained staff and playbooks
AUDIT2-3 WK

GDPR Audit and Gap Assessment

Independent review against current ICO and EDPB guidance. Maturity score, prioritised gap register, executive readout.

  • →Maturity baseline
  • →Gap register, priority-scored
  • →Risk-weighted roadmap
  • →Board-ready readout
04 / SCOPE

Scope of work.

01 / 04

Programme and governance

  • Privacy policy stack
  • Records of Processing (Art. 30)
  • Roles and responsibilities (RACI)
  • Board reporting cadence
  • Privacy-by-design SDLC integration
02 / 04

Operational obligations

  • Data subject request handling
  • Article 33 breach triage and notification
  • DPIAs (Art. 35)
  • Legitimate interest assessments
  • Children and special-category controls
03 / 04

Third parties and transfers

  • Vendor and sub-processor register
  • Article 28 DPA negotiation
  • Cross-border transfer assessments (TIA)
  • SCC implementation and monitoring
  • Joint-controller arrangements
04 / 04

People and evidence

  • Role-based GDPR training
  • Awareness campaigns and phishing tests
  • Internal audit programme
  • Supervisory authority correspondence
  • Annual programme report
05 / DPO-AS-A-SERVICE

Named DPO function.

An external DPO named in your register, available to staff and supervisory authorities. Article 38 independence, no conflict of interest, monthly programme support and on-call breach triage.

Response SLA · DSARs
24 h
Response SLA · breach
4 h
Quarterly steering
Included
DPA registration
We file
See sample engagement letterPDF · 6PP
SAMPLE.MONTHLY.READOUTOCT 2026
DSARs14 / 14 in SLA
Breach incidents2 triaged, 1 notified
DPIAs delivered3
New vendors onboarded7 / DPA signed
Open risk register12 items · 0 high
Authority correspondence1 voluntary submission
SIGNED. IVANA ŠARIĆ, DIRECTOR. REGULATORY STRATEGY
06 / SELECTED WORK

Recent engagements.

All case studies →
CASE 01Pharmaceutical · 4,000 employees

Full GDPR programme passed DPA audit with zero findings.

0
Audit findings
4 mo
Time to audit-ready
€3.2M
Fines avoided
SCOPEGDPR · DPIAs · Vendor risk · DPO-aaS
CASE 02Pan-EU e-commerce

Cross-border transfer assessments after Schrems II. 47 vendors remediated.

47
Vendors assessed
47
TIAs completed
92%
Remediation
SCOPEArt. 46 transfers · TIA · SCCs · Vendor renegotiation
CASE 03B2B SaaS · 200-person

Outsourced DPO covering 11 EU jurisdictions on a single retainer.

11
Jurisdictions
~90
DSARs / month
7 d
Avg cycle
SCOPEDPO-aaS · DSAR ops · Authority liaison
07 / WHY THIS MATTERS

Enforcement landscape.

€5.88B
Total GDPR fines issued (2018-2025)
€1.2B
Largest single fine (Meta, 2023)
2,170+
Public enforcement decisions tracked
72 h
Article 33 breach notification window
TREND 01

Cross-border enforcement is now the default

EDPB consistency mechanism resolved 38 disputes in 2025. Lead-authority shopping has effectively ended.

TREND 02

Special-category data carries premium fines

Health, biometric and children's data drive multipliers. AI trained on customer data sits in this risk class.

TREND 03

DSARs are weaponised

Volume up 3.4× in five years. Failures account for one in five complaints to authorities.

08 / FAQ

Common questions.

01Do we actually need a DPO?+

Article 37 mandates one for public bodies, large-scale monitoring, and large-scale special-category processing. Many organisations under that threshold still appoint one as a matter of governance and to satisfy customer due diligence.

02Can an outsourced DPO be named to the supervisory authority?+

Yes. Article 37(6) explicitly permits a service-contract DPO. We are named on your register, identifiable to staff and authorities, and reachable by data subjects.

03How quickly can you stand up a programme?+

A working baseline (RoPA, core policies, DSAR process, breach playbook) in 6 weeks. Audit-ready maturity in 12-16 weeks for a typical mid-market organisation.

04Will you work alongside our internal counsel?+

Yes. Most engagements run that way. We deliver evidence and operations. Legal counsel keeps strategic privilege. We integrate via your matter-management or ticketing system.

05What happens at a supervisory authority enquiry?+

We respond as DPO of record, prepare the evidence pack, brief executives, and attend the meeting. Pre-supervisory readiness reviews are part of the DPO-aaS retainer.

06Can the same engagement cover GDPR and AI Act obligations?+

Yes. Our DPIA template extends to combined GDPR and AI Act assessments, and the records architecture serves both. See the Technology & AI sector page for AI Act-specific scope.

09 / RESOURCES

Templates and guides.

10 / RELATED PRACTICES

Related practices and guides.

NIS2

Cybersecurity & NIS2

Same incident, two clocks. NIS2 layers a 24-hour CERT warning on top of the GDPR 72-hour notification.

Open practice →
AI ACT

AI Compliance

Article 35 DPIA extends to AI Act conformity. Same DPO, same records spine.

Open practice →
INCIDENT

Incident Response

Pre-built breach playbooks, DPA notification templates, crisis-team coordination.

Open practice →
DPO

DPO as a Service

External data protection officer: compliance monitoring, staff advice and contact with the supervisory authority.

View the service →
TRAINING

GDPR Training

Staff training on data subject rights, consent and personal data breach reporting.

View the training →
TOOL

GDPR Readiness Assessment

15 questions on lawful basis, consent, data subject rights and breach reporting, with a score and a list of gaps.

Open the tool →
GUIDE

GDPR Compliance Guide

A practical guide to GDPR scope, principles, lawful bases, rights, governance, security, DPIAs, transfers, and evidence.

Read the guide →
GUIDE

GDPR Compliance Checklist 2026

An evidence-based GDPR checklist covering scope, lawful processing, rights, vendors, security, DPIAs, transfers, and governance.

Read the guide →
GUIDE

GDPR Data Mapping & ROPA Guide

How to build a useful GDPR data map and records of processing activities without confusing the two.

Read the guide →
GUIDE

Privacy Impact Assessment Guide

How to screen for and complete a GDPR data protection impact assessment before high-risk processing starts.

Read the guide →
GUIDE

Standard Contractual Clauses Guide

How to use the European Commission's 2021 SCCs for international transfers, select modules, assess effectiveness, and maintain evidence.

Read the guide →
GUIDE

GDPR for US Companies

How US companies should assess EU GDPR scope, representation, lawful processing, transfers, vendors, and operational compliance.

Read the guide →
11 / GET STARTED

Start your GDPR programme.

Free initial meeting. Clear next steps. Indicative pricing within one business day.