Engage Compliance helps US tech companies enter the EU market with full GDPR compliance, EU Representative appointment, international data transfer mechanisms, and ongoing outsourced DPO support from a single provider.

An outsourced DPO is a senior data protection expert who manages your entire privacy compliance program: building policies, handling data subject requests, managing vendor risk, supporting enterprise deals, responding to breaches, and engaging with regulators on your behalf. 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.

Key takeaways

  • Most US SaaS companies can achieve EU compliance in 4-8 weeks
  • You may need both a DPO and an EU Representative (we take one role and arrange the other through a trusted partner entity)
  • We cover ongoing compliance so you don’t have to think about it after initial setup

What US companies face when entering the EU

US companies entering the EU market face a wall of privacy requirements: GDPR compliance, appointing an EU representative (Article 27), international data transfer mechanisms, cookie consent, and often appointing a DPO.

Most of this is manageable if you set it up correctly from the start. It becomes expensive and painful when you don’t.

You work directly with a senior DPO. Experience across 100+ companies including Amazon, Coinbase, and Robinhood. We’ve helped US tech companies navigate EU expansion without slowing down their go-to-market.

What we handle for US to EU expansion

  • GDPR gap assessment: what you need vs what you already have
  • EU Representative appointment under Article 27 (provided through a separate designated individual from your DPO, in line with EDPB guidance on operational separation)
  • International data transfer assessments (Standard Contractual Clauses, Transfer Impact Assessments, and EU-US Data Privacy Framework certification guidance)
  • Cookie consent and ePrivacy compliance
  • Full privacy documentation tailored for EU requirements
  • Ongoing DPO services if you need a named officer in the EU
  • NIS2 compliance if your company falls in scope
  • EU AI Act readiness if your product uses AI

Common mistakes US companies make

Assuming CCPA compliance covers GDPR. It doesn’t. GDPR requires a lawful basis for processing, stricter consent requirements, DPO appointment in certain cases, and data transfer mechanisms. CCPA compliance is a starting point, not a substitute.

Ignoring the EU Representative requirement. If you’re outside the EU but offer services to EU residents, you likely need an EU Representative under Article 27. This is separate from a DPO. Failure to appoint one is itself a GDPR violation.

Using US-style cookie consent. EU cookie consent requires opt-in before non-essential cookies fire. A “by continuing to browse” banner doesn’t cut it under the ePrivacy Directive.

Treating EU expansion as a one-time project. GDPR compliance is ongoing. New features, new markets, new vendors, and new enterprise customers all create new compliance requirements. An ongoing DPO retainer handles this.

Beyond the EU

Expanding further? We cover 30+ regulations across the UK (UK GDPR), Brazil (LGPD), Canada (PIPEDA), Thailand (PDPA), China (PIPL), India (DPDPA), Japan (APPI), South Korea (PIPA), UAE, Saudi Arabia, and more. One point of contact for all of it, with local counsel support where jurisdiction-specific legal advice is required. See our Global Privacy Compliance page.

How it works

Month 1: We assess your current state, identify gaps, build your EU privacy framework, notify the supervisory authority of the DPO appointment (if needed), and set up your EU representative.

Month 2+: Ongoing compliance, enterprise deal support for EU customers, and privacy reviews for new features or markets.

Investment

Most US companies expanding to the EU start with DPO Essentials (From €2,000 per month) or DPO Premium (From €5,000 per month) if they need multi-jurisdictional coverage. We also handle standalone EU Representative appointments from €59 per month. See our EU Representative Service page for details.

  • Same-business-day response
  • Professional indemnity and cyber insurance
  • Named DPO notified to the supervisory authority

FAQ

Frequently asked questions

Do I need an EU Representative?

If your company is based outside the EU but offers goods or services to EU residents or monitors their behavior, you likely need one under GDPR Article 27. It's a separate function from a DPO.

Can the EU Representative and DPO be the same person?

No. EDPB guidance indicates one provider should not act as both your DPO and your EU Representative for the same company, to preserve DPO independence. We take one role and arrange the other through a trusted partner entity, keeping the two functions independent.

What are Standard Contractual Clauses?

SCCs are the most common legal mechanism for transferring personal data from the EU to countries without an adequacy decision. For transfers to the US, companies may also use the EU-US Data Privacy Framework (for certified recipients). We handle the assessment, determine the right mechanism, and implement it.

Do I need an EU Representative if I have an EU subsidiary?

Generally no. If you have an establishment in the EU (including a subsidiary), the Article 27 EU Representative requirement typically does not apply. However, you may still need a DPO depending on your processing activities.

How long does EU compliance take?

For a typical US SaaS company with 20-100 employees, the core setup takes 4-8 weeks. Ongoing maintenance is part of the retainer.

Do we need separate compliance for the UK?

Yes. Post-Brexit, the UK has its own GDPR (UK GDPR) and its own supervisory authority (ICO). The requirements are very similar to EU GDPR but legally separate. We cover both.