The Complete Guide to DPO as a Service (DPOaaS)

When you're trying to expand internationally and close deals in the EU or UK, your organization needs to meet GDPR requirements. This often means having a Data Protection Officer (DPO) in place. Without a DPO, your pipeline will stall as EU and UK organisations won’t be able to sign deals with you. 

But for many startups, a full-time DPO is overkill. That is exactly what DPO as a Service (DPOaaS) solves.

In this guide, I’m going to break down exactly how the service model works, why you can’t just appoint your CTO to this role, and how to use an external DPO to speed up your sales cycle.

What is DPO as a Service? 

DPO as a Service is the outsourcing of the Data Protection Officer role to a qualified external expert (usually a privacy / compliance expert or certified practitioner) to satisfy General Data Protection Regulation (GDPR) Article 37 requirements without incurring full-time executive headcount costs.

Instead of hiring a full-time employee, you pay a monthly or annual subscription to a firm that acts as your named DPO. They handle the statutory requirements like monitoring compliance, training staff, and acting as the contact point for authorities, while you focus on shipping your product and building your business. 

An outsourced DPO will bring all the necessary knowledge of GDPR and the EU market to ensure your business complies with European data protection laws and regulations. 

Can My CTO be DPO?

For many organizations the initial reaction to understanding they need to appoint a DPO is: "I'll just name my CTO or VP of Engineering as the DPO in our privacy policy."

However, you can’t do this. Under GDPR Article 38(6), the DPO must be independent. The core principle is that you can’t have the person who determines how and why data is processed (like a CTO or CEO) also be the person responsible for auditing that processing. GDPR sees that as a conflict of interest. Think of it like a student marking their own homework.

If you put your CTO down as your DPO on a security questionnaire for a German enterprise client, there is a high likelihood they will flag that as a compliance issue. An external DPO service solves this instantly because they are contractually independent.

This is why many organizations turn to outsourced DPOs or DPO as a service (DPOaaS). 

When Your Business Will Need a DPO

You don’t need a DPO on Day 1 if you are selling B2B SaaS purely to US companies. But there are three specific triggers where you’d be crazy not to bring this in.

Trigger 1: Selling into Europe

Once you move from selling to SMBs to targeting mid-market or enterprise clients in the EU or UK, your compliance needs will change. These organizations are bound by GDPR laws so any vendor risk management audits will ensure your organization meets GDPR standards, including having a DPO. 

“Once you actively sell into the EU/UK, GDPR applies (Art. 3) and you’ll typically need things like a GDPR-compliant DPA (Art. 28). A DPO becomes legally mandatory only if you meet the Art. 37(1) criteria, but many mid-market and enterprise customers will expect to see a named DPO or equivalent privacy lead in their vendor risk process.”

Once you actively sell into the EU and/or UK, GDPR applies and you’ll need to have a GDPR compliant Data Processing Agreement (DPA). A DPO becomes legally mandatory if you meet the GDPR Art. 37(1) criteria:

• You’re a public authority.
• Your core activities involve large-scale, regular and systematic monitoring of individuals; or
• Your core activities involve large-scale processing of special-category.

However, even outside of the Art. 37(1) criteria, the majority of mid-market or enterprise organizations in the EU and UK will expect to see a named DPO as part of your DPA. If you don’t have one, this can delay deals and stall your funnel. 

Trigger 2: If You Handle Special Category Data

If your product’s core activities involve processing special category data on a large scale, GDPR Article 37 makes appointment of a DPO mandatory.

Special category data includes:

• Health data (PHI)
• Biometric data (facial recognition, fingerprinting)
• Political opinions or trade union membership
• Religious beliefs
• Sexual orientation
  

Trigger 3: Large-Scale Behavior Monitoring

This is the catch-all for AdTech and many AI companies. If your core activity involves "regular and systematic monitoring of data subjects on a large scale," you need a DPO.

This covers:

• Behavioral advertising and tracking.
• AI models that profile user behavior.
• Location tracking apps.

If you fall into this bucket, you will be under high scrutiny from regulators and will need an experienced DPO.

DPO Costs: Full-time vs. Outsourced

For 95% of companies I work with, a full-time DPO is overkill. If you’re hiring full-time, a qualified privacy professional in London, Dublin, or Berlin is expensive. You’re looking at salaries of €100k - €140k ($110k - $150k), plus recruiting overheads and the cost of your time. 

If you outsource, you’re likely looking at $1,000-1,500/month at the lower end or $2,500-3,000+/month if you operate in a highly regulated sector. So generally, the outsourced option makes financial sense. 

The ROI of Your Investment

When you begin working with an outsourced DPO or DPO as a Service company, the real value isn’t the cost savings vs. hiring someone full-time, it’s the revenue unblocking. 

A DPOaaS allows you to flex expertise into your sales cycle. When a prospect asks a question about your sub-processors or data transfer mechanisms, your DPO can draft a legally sound response to help you win the deal.

What does a DPO actually do? 

A DPOaaS provider delivers structured, proactive privacy management. Here is what you should expect from the scope of work:

1. The "Named" Individual

You get a specific, qualified individual to list in your privacy policy and public documentation. They serve as the official point of contact for Data Subjects (your users) and Supervisory Authorities (the regulators). If a user emails privacy@yourcompany.com demanding their data be deleted, the DPO guides the response.

2. DPIAs and Roadmap Reviews

This is critical for product teams. Before you launch a high-risk feature (like a new AI tool that trains on customer data) your DPO should conduct a Data Protection Impact Assessment (DPIA).

This isn't just paperwork. It's a risk mitigation strategy. They will look at your architecture and say to catch any potential privacy issues before you ship code, ensuring every new feature meets GDPR regulations. 

3. Breach Response

Under GDPR, you have 72 hours to report a serious data breach to regulators. Your DPO service acts as the first responder for the legal side of the breach. While your engineering team gets to the bottom of the issue and gets a fix in place, the DPO manages the communication with the Information Commissioner's Office (ICO) or other authorities to minimize fines.

What a DPO does NOT do

• They do not implement technical fixes. They will tell you that your encryption is insufficient, but they will not log into AWS to configure your S3 buckets.
• They do not make business decisions. They advise on risk. Your organization’s leadership then decides whether to accept that risk.
• They do not guarantee Instant Compliance. Hiring a DPO is like hiring a building inspector. It doesn't mean your house is built yet. It marks the start of the compliance journey, not the end.

DPO vs. vCISO

I often see founders confuse the role of a DPO with a vCISO (Virtual CISO). While they’re both fractional security experts, they have different focuses. 

A DPO is focused on privacy rights (GDPR, CCPA). They care about "Are we allowed to collect this?" and "Did the user consent?" They are usually lawyers or privacy specialists. Whereas a vCISO focuses on security controls, frameworks (SOC 2, ISO 27001), and implementation. A vCISO is a more technical security leader.

Do You Need Both?

Often, yes. Ideally, these two work in tandem. Workstreet’s vCISO service builds the technical security program and governance structure that protects your data, while our DPO handles the regulatory permissions to use that data.

If you have a DPO but no CISO, you might be legally compliant but technically vulnerable. If you have a CISO but no DPO, you might be secure but legally exposed. Together, they form a complete trust center around your business. 

For a deeper dive on choosing security leadership, check out my guide on vCISO vs. CISO.

How Workstreet Can Support Your Organization

At Workstreet we offer GDPR compliance for modern tech companies. We’ll put a right sized privacy program in place to address GDPR without slowing down. 

Our team are experts in GDPR and data protection laws and have helped US companies expand in the the UK and EU whilst ensuring compliance. We've crafted policies, mapped controls, and acted as a DPO.

Get in touch with us here or learn more about Workstreet’s GDPR support here.