Most technology companies do not need to hire a full-time Data Protection Officer. They need a senior, independent DPO who is formally notified to the supervisory authority and is available when regulators, enterprise customers, or breaches demand a real answer. That is exactly what an external DPO service provides.

What you get:

  • A named senior external DPO, notified to the supervisory authority where required
  • EU GDPR, UK GDPR, and US state privacy laws covered in one engagement
  • ROPA, data subject requests, vendor reviews, DPIAs, and around-the-clock breach response

What does an external DPO cover?

  • Named DPO, notified to the supervisory authority where required.
  • Record of Processing Activities (ROPA), maintained as your product changes.
  • Data subject access requests (DSARs) handled end to end, to the statutory deadline.
  • Vendor and DPA reviews that unblock enterprise deals and procurement.
  • Breach response managed around the clock when the 72-hour clock is running.
  • DPIAs for higher-risk processing, lawful-basis analysis, and board reporting.

Why "external" is the right model for most tech companies

An in-house DPO typically costs between €80,000 and €150,000 a year including salary, benefits, and overheads. For most technology companies from Seed to mid-Series B, the volume and variety of privacy work does not justify that headcount. An external DPO brings the same senior judgment at a fraction of the cost, and scales with you.

External DPOs are also better placed to maintain the independence that GDPR requires. An in-house hire who reports to the CEO or the legal team faces structural pressure that an external provider does not.

What should I look for in an external DPO provider?

The DPO role carries legal weight. When a supervisory authority contacts your DPO, or when a major enterprise customer asks a hard question in a due diligence questionnaire, the answer needs to come from someone with real experience of how regulators and procurement teams actually behave. Key criteria:

  • EU-established, with details notifiable to the relevant supervisory authority.
  • Senior practitioners, not account managers backed by a junior team.
  • Track record across the industries and risk profiles relevant to your business.
  • Responsive when the clock is running, not ticket-queue support.

The external DPO service for UK companies

The external DPO service works the same way for a UK company as for an EU one. You get a named, senior external DPO whose contact details are notified to the ICO where an appointment is required under UK GDPR, alongside the Data Protection Act 2018. Most UK technology companies appoint one when a first enterprise deal, an investor due diligence process, or a security questionnaire asks who owns data protection, well before the strict Article 37 test bites.

Many UK companies also sell into the EU. The same external DPO service covers UK GDPR and EU GDPR in one engagement, and where an EU Representative is also needed we arrange that through a partner entity so the two roles stay independent. See outsourced DPO for UK companies for the UK-specific detail, and the best outsourced DPO providers in the UK for how the options compare.

Who we work with

We work with technology companies worldwide that handle EU, UK, and US personal data: SaaS, fintech, healthtech, AI, ecommerce, and others. Experience across 100+ startups and enterprises including Amazon, Coinbase, and Robinhood. We are based in Amsterdam, and our plans start from €600 per month.

GDPR is lawful-basis-driven. An external DPO who understands how your product actually processes data is far more valuable than a checklist.

FAQ

Frequently asked questions

What is an external DPO?

An external DPO is a Data Protection Officer provided as a service rather than employed in-house. Under GDPR, the DPO can be an external service provider, and they must be able to act with full independence. An external DPO gives you the senior expertise and named role without the cost and commitment of a full-time hire.

Is an external DPO recognized by data protection authorities?

Yes. GDPR Article 37(6) explicitly permits the DPO to be an external service provider. Where appointment is required or chosen, the DPO's details are notified to the relevant supervisory authority. We are EU-established as Engage Data Consulting BV in the Netherlands.

Do I need an external DPO?

A DPO is mandatory if you are a public authority, your core activities involve large-scale regular monitoring of individuals, or you process special-category data at large scale. Many technology companies appoint one voluntarily because enterprise buyers and investors expect a named privacy contact. An outsourced or external DPO is the most efficient route for most tech companies.

Can the same provider be our DPO and our EU Representative?

Not for the same client. The EDPB is clear that one provider cannot serve as both DPO and EU Representative for the same company, because the roles can conflict. We will help you structure both functions correctly.

How much does an external DPO cost?

Privacy Advisory is €600 per month. A named DPO starts at €1,000 per month with DPO Foundation, hands-on support starts at €2,500 per month with DPO Partner, and an embedded DPO starts at €4,500 per month with DPO Complete, with custom scoping at enterprise scale. All prices are billed annually, and one-time onboarding is waived on annual billing.

What is an external DPO service?

An external DPO service is the statutory Data Protection Officer role delivered by an outside provider on a subscription, rather than filled by an in-house hire. Under GDPR Article 37(6) the DPO can be an external service provider, so the appointment carries the same legal standing. It is the same offering as an outsourced, virtual, or fractional DPO, with the DPO notified to the supervisory authority where required.

Is there a UK version of the external DPO service?

Yes. For UK companies the external DPO service covers UK GDPR and the Data Protection Act 2018, with the DPO's contact details notified to the ICO where an appointment is required. Where you also serve EU customers, the same engagement covers EU GDPR, and an EU Representative can be arranged through a partner entity so the two roles stay independent.