DPO as a Service – The Challenge

Under the General Data Protection Regulation (GDPR), many organisations must appoint a Data Protection Officer (DPO) to ensure compliance with data protection laws. However, finding, hiring, and retaining an experienced and independent DPO can be both challenging and costly.

What if you could meet your GDPR obligations without the overhead of a full-time hire? That is where our Outsourced DPO service, also known as DPO as a Service, comes in.

What is DPO as a Service?

Our DPO as a Service provides your organisation with access to an experienced Data Protection Officer who acts as an extension of your team. This tailored solution bridges the gap between your compliance obligations and your internal resources, offering expertise and flexibility.

We serve clients across Ireland and beyond, helping them navigate GDPR, respond to compliance challenges, and strengthen their data protection policies and processes.

DPO as a Service providers typically offer a range of services, including but not limited to:

As part of our DPO as a Service offering, we provide:

  • Gap Analysis: Identify areas of non-compliance and risks.
  • Data Mapping (ROPA): Create and maintain Records of Processing Activities.
  • Policy Development: Review and implement robust data protection policies.
  • Training and Awareness: Equip your team with the knowledge to handle GDPR compliance.
  • Data Breach Management: Rapid response and support for incident management.
  • Privacy by Design: Embed privacy principles into your processes and products.
  • Third-Party Risk Assessments: Ensure compliance across vendors and partners.
  • Cross-Border Compliance: Navigate privacy laws beyond the EU, including the EU-US Data Privacy Framework.

Our DPO as a Service Offering

Our DPO-as-a-Service offering is popular with clients who require a Data Protection Officer and where this is not a full-time role. Clients benefit from experienced, objective professionals who are skilled at board-level communication and have a track record of implementing effective Data Protection processes and practices, as well as associated documentation and audits. Finally, we offer the services of our Data Protection Consultants to provide support to the newly appointed or under-resourced Data Protection Officer in many organisations.

 

Why you may need DPO aaS?

Scenario 1 – Maturing Data Protection Strategy

You may already have achieved some compliance or quality standards and you need to build on that to meet new obligations or meet more sophisticated threats to your business.

Scenario 2 – Little or No Data Protection Strategy

On the other hand, you may have very little in-house knowledge around security and compliance. In that case we can provide you with a fully managed program of building the systems and processes in your business to become compliant with GDPR and other regulations that may affect you, such as PCI DSS.

Benefits of DPO as a Service


Cost-Effective Compliance:

Reduce the high costs associated with hiring a full-time DPO.


Tailored Solutions:

Receive a personalised approach aligned with your organisation’s needs.


Expert Guidance:

Leverage the knowledge of senior consultants with broad industry expertise.


Unbiased Oversight:

Ensure independence and avoid conflicts of interest, as required by GDPR.


Protect Sensitive Data:

Safeguard critical information and minimise the risk of breaches, fines, and reputational damage.


Focus on Core Business:

Free your internal team to focus on strategic priorities.

Why choose Commsec as your dpo provider?

We are a trusted DPO provider with a proven track record of delivering DPO as a Service in Ireland and internationally. Our team of seasoned data protection specialists ensures that you receive expert advice and support tailored to your industry and business size.

FAQ's

A DPO (Data Protection Officer) is a person appointed by an organisation to oversee data protection compliance and ensure that personal data is handled in accordance with laws and regulations, such as the General Data Protection Regulation (GDPR) in the European Union (EU).

DPOs are responsible for monitoring the organisation’s compliance with data protection laws and regulations, providing advice and guidance on data protection matters, and ensuring that individuals’ rights are protected. They also act as a contact point for data subjects, supervisory authorities, and other stakeholders on data protection matters.

The role of DPO is independent; DPOs must report to the highest management level of the organisation and must not receive any instructions regarding the exercise of their tasks.

Principles of Data Processing

GDPR outlines several principles for processing personal data:

  • Lawfulness, Fairness, and Transparency: Data must be processed lawfully, fairly, and in a transparent manner.
  • Purpose Limitation: Data should be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
  • Data Minimization: Only data that is necessary for the intended purpose should be collected.
  • Accuracy: Personal data must be accurate and kept up to date.
  • Storage Limitation: Data should be kept in a form that permits identification of data subjects for no longer than necessary.
  • Integrity and Confidentiality: Data must be processed in a manner that ensures appropriate security. Source

Rights of Data Subjects

GDPR grants several rights to individuals, including:

  • Right to Access: Individuals can request access to their personal data.
  • Right to Rectification: Individuals can request correction of inaccurate data.
  • Right to Erasure: Also known as the “right to be forgotten,” individuals can request deletion of their data under certain conditions.
  • Right to Restrict Processing: Individuals can request the restriction of processing their data.
  • Right to Data Portability: Individuals can request to receive their data in a structured, commonly used, and machine-readable format.
  • Right to Object: Individuals can object to the processing of their data in certain circumstances.

Data Controller and Processor Responsibilities

  • Data Controllers: Organisations that determine the purposes and means of processing personal data must ensure compliance with GDPR principles.
  • Data Processors: Organisations that process data on behalf of data controllers must also comply with GDPR and ensure data protection.

Organisations may be required to appoint a DPO to oversee GDPR compliance, especially if they process large amounts of personal data or sensitive data.

Data Breach Notification

  • Organisations must report certain types of data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach.
  • If the breach poses a high risk to individuals’ rights and freedoms, the affected individuals must also be informed.

Penalties for Non-Compliance

  • GDPR imposes significant fines for non-compliance, with penalties of up to €20 million or 4% of the annual global turnover, whichever is higher.

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