The term "virtual DPO" reflects how privacy work is done now: experienced data protection experts work remotely with technology teams every day, and for a growing tech company that is usually the practical way to fill the role.
What you get:
- A named expert 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
Key takeaways
- "Virtual DPO" describes how the role is delivered, not a lesser version of it. GDPR treats an in-house and an external Data Protection Officer identically.
- Engage Compliance works asynchronously for routine matters and is available synchronously when something escalates, which for most teams means a shared channel, email, and a regular call.
- Breach response does not depend on being in the building: triage, the 72-hour notification assessment, and data subject communication are all handled remotely.
- Your named DPO is in place and onboarding is done within one day of signing. Onboarding opens with a conversation about your data architecture, not a questionnaire. Ongoing cover is priced on Pricing.
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 program.
How it works in practice
Onboarding
We start learning your data architecture, processing activities, and risk profile on day one, with onboarding done within one day of signing. 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 program
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 with the same level of expertise 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 an experienced 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 asks you to justify each use of personal data with a lawful basis, and a policy library cannot do that for you. A virtual DPO who understands your technology and your market can.