Hire a named expert DPO, notified to the supervisory authority and ready for enterprise buyers, investors, and regulators, without a full-time salary.
What you get:
- A named expert DPO instead of a full-time hire
- EU GDPR, UK GDPR, US state laws, EU AI Act, NIS2, and DORA covered
- Vendor questionnaires, data subject requests, and breach response handled to deadline
Whatever the trigger, this page covers the practical question: how do you actually hire a DPO, what does it cost, and what options exist.
Key takeaways
- You can hire a named expert DPO, notified to the supervisory authority, without a full-time salary.
- Outsourcing is often faster and more flexible than an in-house hire.
- Compare providers on who the named DPO is, where they are established, and whether they publish prices.
- Engage Compliance is the outsourced option on this page, and we will tell you if a full-time hire is the better call.
What a DPO actually does
Under GDPR Article 39, the DPO monitors compliance with the GDPR, advises the controller on data protection obligations, cooperates with the supervisory authority, and acts as the point of contact for data subjects and regulators.
In practice, this translates to ongoing operational work: maintaining Records of Processing Activities, drafting and reviewing privacy notices, advising on new processing activities, and conducting Data Protection Impact Assessments. It also covers handling vendor and sub-processor reviews, responding to data subject rights requests, managing personal data breaches, and supporting enterprise procurement teams with vendor questionnaires and DPA negotiations.
The DPO is not personally liable for the company’s compliance. The controller and processor remain legally responsible. But the DPO is the company’s privacy expert and operational point of contact.
Should I hire a DPO or outsource?
Option 1: Full-time in-house DPO
A dedicated employee fully focused on your company. Cost in the EU: €80,000 to €150,000 per year in salary, before recruitment, benefits and employer costs. US equivalent: $130,000 to $220,000 fully loaded.
Pros: Dedicated capacity, deep institutional knowledge over time, cultural integration with engineering and product teams, available 24/7 for incidents.
Cons: High cost, recruitment takes 3 to 6 months, severance risk, may be overkill for companies with variable privacy workload.
Right for: Companies with 500 plus employees, heavily regulated industries (banking, healthcare provider operations, telecommunications), or companies processing personal data at very large scale where the workload realistically requires full-time attention.
Option 2: Fractional or outsourced DPO
An experienced privacy practitioner engaged on retainer to perform the DPO function on a part-time basis. Cost: €500 to €7,500 per month, depending on company size and complexity.
Pros: Lower cost, immediate access to specialist expertise, faster to engage (typically within 1 to 2 weeks), no recruitment cost, no severance risk, easier to scale up or down based on need.
Cons: Less culturally embedded than an in-house hire, less available for very rapid response than a dedicated employee.
Right for: Technology companies with 20 to 300 employees at Seed through Series C funding stages. Most growing tech companies fit this profile.
This service is variously referred to as external DPO, virtual DPO, fractional DPO, or DPaaS (DPO as a Service). All four terms refer to the same service model: a qualified Data Protection Officer provided by an external firm on a retainer basis, rather than a full-time employee. “External DPO” is the dominant term in UK and EU markets. Local-language equivalents include externer Datenschutzbeauftragter (Germany), DPO externe (France), DPO esterno (Italy), and DPD externo (Spain). “Outsourced DPO” is common in international contexts. “Fractional DPO” is more common in US startup parlance. The legal standing and responsibilities are identical under GDPR Article 37(6).
Option 3: Internal DPO with no privacy background
Appointing an existing employee (often from legal, compliance, or HR) as DPO while continuing their other responsibilities. This is technically permitted under GDPR Article 38(6) where this does not give rise to a conflict of interest.
Pros: Lowest visible cost.
Cons: The employee is rarely qualified for the role. The company carries unmitigated compliance risk. Supervisory authorities often question the adequacy of these arrangements. The no conflict of interest requirement is widely violated in practice.
Right for: Almost no situation. This is usually a compliance pretense rather than a real solution.
What to look for in a DPO
Documented privacy experience: real prior privacy roles at recognizable organizations, rather than general counsel who picked up privacy along the way.
IAPP certifications. CIPP/E (Europe), CIPP/US (United States), CIPM (privacy management), AIGP (AI Governance Professional).
Sector relevance. Privacy work in healthcare is different from privacy work in SaaS. Look for experience matching your sector.
Operational experience. Has the candidate actually responded to DSARs, managed breaches, dealt with supervisory authorities? Theoretical privacy knowledge is not the same as operational ability.
Communication skills. The DPO interfaces with executives, engineering, sales, legal, and external parties. Strong written and verbal communication matters.
Independence. The DPO must be able to challenge the company’s processing where appropriate. A DPO who only agrees with leadership is not doing the job.
How fast can you hire a DPO?
A full-time DPO recruitment takes 3 to 6 months from job posting to start date. Specialist privacy recruiters typically charge 20 to 30 percent of first-year salary.
A fractional DPO engagement typically starts within 1 to 2 weeks of contract signature. Engage Compliance starts within one day of signing.
If you have an immediate trigger (enterprise deal, regulator inquiry, breach, investor due diligence), fractional is the only realistic option in the short term. You can engage fractional while recruiting full-time if that is your end state. If your existing DPO has just left, what to do when your DPO leaves covers the first week.
How to evaluate fractional DPO providers
If you go with a fractional or outsourced DPO, evaluate providers on:
- Specialist expertise. You should work directly with an experienced practitioner, not a junior consultant rotating off a team.
- Documented experience. The provider should be able to point to specific prior privacy leadership roles at recognizable organizations.
- Pricing transparency. Most providers in this category do not publish pricing. Those who do tend to be more confident in their value proposition.
- Multi-jurisdictional coverage. Most growing tech companies have EU, UK, and US customers. A DPO who only covers one jurisdiction creates gaps.
- Insurance. Professional indemnity insurance on engagements protects you and shows the provider is serious.
- Operational scope. Confirm what is included: DSARs, breach response, vendor questionnaires, supervisory authority notification, enterprise deal support.
- Notice period. Reasonable notice for termination (typically 30 to 90 days) protects both parties.
How Engage Compliance fits
Engage Compliance is an expert-led fractional DPO and privacy compliance consultancy based in Amsterdam, Netherlands. Experience across 100+ startups and enterprises, including Amazon, Coinbase, Robinhood, Fanatics, Medtronic, AbbVie, IKEA, Nestle and Hopin.
Pricing: Privacy Advisory From €600 per month. DPO Foundation From €1,000 per month. DPO Partner From €2,500 per month. DPO Complete From €4,500 per month.
Coverage: EU GDPR, UK GDPR, EU AI Act, CCPA/CPRA, 20 US state privacy laws, NIS2, DORA, HIPAA where relevant, plus global frameworks. EU establishment for Article 37 appointment purposes.
Cost and scope differ by provider type: a large software-assisted vendor, a UK technical privacy specialist and a law firm retainer each make different trade-offs. For the roles themselves, read data protection officer services and our fractional DPO page.
Get started
Book a consultation to discuss your DPO needs.
Sources and references
- Regulation (EU) 2016/679 (GDPR), official text, EUR-Lex
- UK GDPR (Regulation (EU) 2016/679 as it forms part of UK law), legislation.gov.uk
- Article 29 Working Party Guidelines on Data Protection Officers (WP243 rev.01), endorsed by the EDPB, European Commission (Article 29 Working Party archive)
- ICO (UK): Data protection officers, Information Commission (UK)
- Regulation (EU) 2024/1689 (EU AI Act), official text, EUR-Lex
- Directive (EU) 2022/2555 (NIS2), official text, EUR-Lex
- Regulation (EU) 2022/2554 (DORA), official text, EUR-Lex