Polish companies operate under GDPR with Polish-specific implementation through the Act of 10 May 2018 on the Protection of Personal Data. The Urzad Ochrony Danych Osobowych (UODO), Poland’s Personal Data Protection Office, is the Polish data protection supervisory authority. For Polish tech companies, DPO appointment follows the general GDPR test, with Polish law adding its own notification procedure.
The short answer: a Polish company appoints a DPO under GDPR Article 37, notifies the President of the UODO within 14 days of the appointment under Article 10(1) of the Polish Data Protection Act, and can fill the role on a service contract rather than a hire.
Engage Compliance acts as the named DPO for Polish companies, notified to the UODO, with the same senior person on the account throughout. Experience across 100+ startups and enterprises including Amazon, Coinbase, and Robinhood.
Key takeaways
- Polish companies operate under GDPR plus the Act of 10 May 2018 on the Protection of Personal Data, supervised by the UODO.
- The Polish Act mainly clarifies which public bodies must appoint a DPO (public finance sector units, research institutes, the National Bank of Poland) and sets the UODO notification procedure.
- DPO appointment is notified to the President of the UODO within 14 days, electronically, with a qualified signature or an ePUAP trusted profile.
- Named DPO tiers start From €1,000 per month, against 15,000 to 25,000 zloty a month for a full-time Polish hire before full employer costs.
Does a Polish company need a DPO
Under GDPR Article 37, appointment is required for a public authority or body, for core activities requiring large-scale regular and systematic monitoring, or for large-scale processing of special category data.
Poland’s Act of 10 May 2018 does not add a broad private-sector list the way some other member states do. It clarifies the public-authority category instead, naming public finance sector units, research institutes, and the National Bank of Poland as bodies that must appoint a DPO. Most Polish SaaS, fintech, and healthtech companies sit outside that list and are governed by the general Article 37 test, with many appointing a DPO voluntarily because enterprise customers and investors expect it during security review.
UODO notification
DPO appointment is notified to the President of the Urzad Ochrony Danych Osobowych under Article 10(1) of the Polish Data Protection Act, within 14 days of the designation, giving the DPO’s name and either an email address or phone number. The filing is submitted electronically, signed with a qualified electronic signature or an ePUAP trusted profile signature. We complete this notification as part of onboarding and give you the confirmation for your own records.
Polish language considerations
The formal UODO filing and most data subject communications are expected in Polish. For an outsourced arrangement without a Polish-speaking DPO, translation and Polish-language coordination need to be addressed for those specific touchpoints; the day-to-day advisory work runs the same as anywhere else.
What it costs
- DPO Foundation, From €1,000 per month.
- DPO Partner, From €2,500 per month.
- DPO Complete, From €4,500 per month.
- Privacy Advisory, From €600 per month, advice without a named appointment.
An experienced full-time DPO in Poland typically runs 15,000 to 25,000 zloty a month in gross salary, before full employer costs, plus several months of recruitment in a market where privacy specialists are scarce. See the outsourced DPO cost guide for the full comparison.
Why Engage Compliance
You work with a senior DPO directly, the same person throughout, notified to the supervisory authority. Experience across 100+ startups and enterprises including Amazon, Coinbase, and Robinhood. Your DPO is an expert, never a junior handoff. This Polish engagement follows the same outsourced DPO services model we run everywhere, and every engagement carries professional indemnity and cyber insurance.
Sources and references
- Regulation (EU) 2016/679, General Data Protection Regulation, Articles 30, 33, 35, 37, 38 and 39
- Act of 10 May 2018 on the Protection of Personal Data (Dz.U. 2018 item 1000), Article 10
- Urzad Ochrony Danych Osobowych (UODO)