The term "virtual DPO" reflects how modern privacy work is actually done. Senior data protection experts work remotely with technology teams every day. For a growing tech company, a virtual DPO is not a compromise on the role, it is often the most effective way to fill it.

What you get:

  • A named senior virtual 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 breach response handled to deadline

What does a virtual DPO cover?

A virtual DPO covers the same scope as an in-house DPO. GDPR does not distinguish between the two models. The role includes:

  • Named DPO, formally appointed and notified to the supervisory authority where required.
  • Lawful-basis analysis and privacy-by-design input on new product features.
  • Record of Processing Activities (ROPA) maintained as the product evolves.
  • Data subject access requests and deletion requests handled to statutory deadlines.
  • Vendor and DPA review for procurement and enterprise deals.
  • Data Protection Impact Assessments (DPIAs) for higher-risk processing.
  • Breach triage, supervisory authority notification, and data subject communication.
  • Board and investor reporting on the privacy programme.

How it works in practice

Onboarding

We learn your data architecture, processing activities, and risk profile in the first two weeks. No questionnaire forms, a direct conversation with your team.

Formal appointment

Your named DPO is formally appointed and, where required, notified to the supervisory authority. You get the documented appointment letter and notification confirmation.

Ongoing programme

ROPA, policies, DSAR handling, vendor reviews, DPIAs, board reports, and breach response. We operate asynchronously and are available synchronously for escalations.

Virtual DPO or in-house DPO?

An in-house DPO typically costs between €80,000 and €150,000 per year. A virtual DPO service at the same seniority level costs a fraction of that. Beyond cost, the in-house model creates a structural tension: an employee DPO who reports to management is harder to keep independent, which is precisely what GDPR requires.

A virtual DPO from an external provider maintains that independence by design. When a data subject or a supervisory authority contacts your DPO, they reach a senior practitioner who is not accountable to your board for their privacy decisions.

EU-established and UK-covered

We are based in Amsterdam, which means your virtual DPO is notifiable to EU supervisory authorities directly. We also cover UK GDPR and work with companies that have US operations under applicable US privacy laws (CCPA, VCDPA, CPA, TDPSA, and others). One team, one engagement.

GDPR is lawful-basis-driven, not checkbox-driven. A virtual DPO who understands your technology and your market is worth more than a policy library.

FAQ

Frequently asked questions

What is a virtual DPO?

A virtual DPO is a Data Protection Officer who delivers the full scope of the role remotely, without being employed in-house. The term is interchangeable with outsourced or external DPO. GDPR Article 37(6) permits the DPO to be an external service provider, and the role is recognised by supervisory authorities whether delivered in-office or remotely.

Does a virtual DPO have the same legal standing as an in-house DPO?

Yes. GDPR treats an in-house and an external DPO identically. Both must be independent, have expert knowledge of data protection law, and be able to be contacted by data subjects and the supervisory authority. Our DPO details are notified to the relevant supervisory authority in exactly the same way as an in-house appointment.

Can a virtual DPO handle breach response?

Yes, and being remote is no barrier. We have 24/7 breach support included in relevant plans. When a breach is suspected we triage it immediately, assess whether notification is required under the 72-hour rule, draft the supervisory authority notification if needed, and advise on data subject communication.

How does a virtual DPO engage with our team?

We work asynchronously for routine matters, with scheduled check-ins and ad hoc availability for escalations. Most teams find a senior Slack channel, email, and a monthly or quarterly call covers 90% of the ongoing work. We adapt to how your team operates.

How much does a virtual DPO service cost?

Plans start from €500, €2,000, and €5,000 per month depending on the complexity of your processing, the number of jurisdictions, and the volume of day-to-day activity. Every engagement is scoped so pricing starts from these figures.