Data Protection Officer as a Service
Introducing the Service
If your business handles personal data - customer details, employee records, user accounts - you have obligations under UK and EU data protection law. For some organisations, that includes formally appointing a Data Protection Officer (DPO). For others, it's technically optional but practically sensible.
Either way, most small businesses don't need (or can't justify) a full-time privacy specialist. But the work still needs doing: keeping records, handling requests from customers wanting to know what data you hold, making sure your privacy notices are accurate, and knowing what to do if something goes wrong.
Oxford Infosec's DPO service gives you a named, qualified Data Protection Officer who handles your privacy compliance so you don't have to. They're independent (as the law requires), report to your leadership, and act as your formal point of contact with the Information Commissioner's Office (ICO).
This is a practical service, meaning that your DPO will actually do the work - maintaining records, responding to requests, advising on new projects, and keeping you out of trouble with the regulator.
What Problem Does This Solve?
If any of these sound familiar, this service can help:
Someone emails asking what data you hold on them
Panic. Who handles this? What's the deadline? Where's the data? Someone spends days pulling information from different systems.
You're launching a new feature that uses customer data in a new way
Ship it and hope for the best. Or delay while people argue about whether it's allowed.
A laptop gets stolen or someone sends data to the wrong person
Uncertainty about whether to tell the ICO, what to tell customers, and who's responsible for sorting it out.
A customer or partner asks about your privacy practices
Scramble to find (or create) privacy documentation. Answers are inconsistent.
The ICO writes to you
Fear. Who responds? What do we say? Are we in trouble?
You need to appoint a DPO but don't have anyone qualified
Appoint someone who doesn't really understand the role, or leave it vacant and hope nobody notices.
A DPO handles all of this. They know what's required, they do the work, and they deal with the regulator on your behalf.
Fit for Small Businesses
This service is designed for organisations that need proper privacy compliance but don't have the headcount or budget for a full-time specialist. Typically that means:
20 to 200 employees - large enough to have real data protection obligations, small enough that a full-time DPO would be overkill
Handling personal data - customer accounts, employee records, user data, marketing lists, or other information about identifiable people
Operating in the UK or EU - subject to UK GDPR, EU GDPR, or both
Facing questions from customers or partners - procurement questionnaires, due diligence requests, or contractual requirements around data protection
We tailor everything to your size and risk profile. The ICO is clear that smaller organisations need a "smaller-scale approach to accountability" - you don't need the same level of documentation as a bank or a hospital. We focus on what's genuinely required and what's proportionate, not on generating paperwork for its own sake.
Outcomes: What You Get
Compliance without the headache
Someone qualified is responsible for privacy
You have a named DPO with recognised credentials who knows what they're doing
Requests get handled properly
When someone asks for their data or wants to be forgotten, it happens within the legal deadline
You know what data you have and why
Your records of processing are accurate and current - you can answer "what data do you hold?"
New projects get privacy input
Before you launch something that uses personal data in new ways, you get proper advice
Breaches are handled correctly
If something goes wrong, you know what to do, who to tell, and how to document it
The ICO isn't a mystery
You have someone who deals with the regulator professionally if they ever come knocking
Confidence with customers and partners
You can answer privacy questionnaires accurately
No more making things up or hoping for the best
Your privacy notices are correct
What you tell people matches what you actually do
Contracts have the right terms
Data processing agreements are in place with your suppliers and customers
You're not the weak link
Partners and customers can see you take data protection seriously
Peace of mind
You're not guessing
Someone who understands the law is telling you what's required
You're not exposed
If something goes wrong, you can show you had proper oversight
You're not wasting time
Privacy compliance isn't eating into time you should spend on your business
Scope of Activities
Your DPO handles the following:
Core DPO responsibilities
Advice and guidance
Answering questions from your team about what's allowed, what's required, and how to do things properly. Available when you need them, not just at scheduled meetings.
Compliance monitoring
Checking that your privacy practices match your policies. Regular reviews, spot checks, and an annual audit to make sure things are working.
Privacy impact assessments
When you're planning something new that involves personal data (a new product feature, a new supplier, a new way of using data), advising on the risks and what you need to do.
Training and awareness
Making sure your team understands their responsibilities. Induction material for new starters, annual refreshers, and targeted sessions when needed.
Regulator liaison
Acting as your formal contact point with the ICO. If they write to you, your DPO handles the response.
Day-to-day privacy operations
Handling data subject requests
When someone asks what data you hold on them (a Subject Access Request), wants their data deleted, or wants to opt out of something, your DPO manages the response within the legal deadline.
Maintaining your records
Keeping your Record of Processing Activities current - the document that shows what personal data you process, why, and how it's protected.
Reviewing privacy notices
Making sure what you tell people (on your website, in your app, in contracts) matches what you actually do with their data.
Breach management
If personal data is lost, stolen, or exposed, your DPO assesses whether it needs reporting to the ICO, handles the notification if so, and documents everything properly.
Supplier oversight
Checking that suppliers who handle personal data on your behalf have appropriate contracts and security in place.
Retention and disposal
Advising on how long to keep data and making sure it's deleted when it should be.
Compliance platform management (if applicable)
If you use a compliance automation platform, your DPO will:
Configure the GDPR module
Set up the platform with the right controls and policies for your business
Maintain evidence
Keep the platform updated with current documentation and proof that controls are working
Manage tasks
Use the platform's workflow to track policy reviews, training renewals, and other recurring activities
Report from the dashboard
Use the platform's reporting to show your compliance status to leadership
Working with your legal team
Your DPO works alongside (not instead of) your legal advisors:
Contract review
Reviewing data protection clauses in supplier and customer contracts, flagging issues, and suggesting appropriate terms
Legal interpretation
Working with your lawyers when there are genuinely difficult legal questions (novel situations, regulatory grey areas, case law implications)
Incident response
Coordinating with legal on privilege, regulatory strategy, and communications during serious incidents
Regulatory changes
Monitoring for new laws and guidance, assessing impact, and planning any necessary changes
What's Not Included
Legal advice
Your DPO advises on data protection law, not employment law, contract law, or other legal matters. Use your lawyers for those, or if you need a formal legal opinion on a privacy matter.
EU Representative
If you need a representative in the EU (because you're UK-based but processing EU residents' data), that's a separate appointment. We can advise on whether you need one.
Implementing technical controls
If an audit finds you need better encryption or access controls, your DPO will tell you what's needed. Your IT team implements it.
Compliance platform subscription
If you use a compliance automation platform, you pay for the subscription directly. We configure and operate it.
Deliverables
At the start
DPO appointment letter (formal documentation of the appointment); ICO notification (registering your DPO with the regulator); Updated Record of Processing Activities
Quarterly
Compliance report for your leadership - audit results, open issues, recommendations, and trends
As needed
Privacy impact assessment for new projects; Breach documentation and ICO correspondence; Responses to data subject requests
Annually
Board-level presentation on your data protection posture; Refreshed training materials and completion tracking
Governance
Independence
Your DPO reports to your board or senior leadership, not to the team whose work they're overseeing. This is a legal requirement - the DPO needs to be able to give objective advice.
Regular contact
Monthly operational meeting with whoever handles privacy day-to-day (often IT, legal, or operations). Quarterly report to senior leadership.
Availability
Your DPO responds to queries within 2 business days. Faster for urgent matters (potential breaches, regulator contact).
Escalation
If your DPO's advice is being ignored or overridden, they have a direct route to your board chair or a nominated director.
Assumptions
You give us access to what we need
Your DPO needs to see your systems, talk to your people, and review your documentation. If we can't access something, we can't advise on it.
Someone internally coordinates with us
You need a point of contact - someone who can answer questions, chase information, and make sure things happen.
You act on advice
A DPO adds value when their guidance is followed. If recommendations consistently go unactioned, the service won't deliver results.
Technical implementation is your responsibility
We tell you what needs to change; your team makes the changes.
Who Delivers the Service
Your DPO will be a qualified privacy professional holding recognised credentials, such as:
CIPP/E
Certified Information Privacy Professional/Europe - demonstrates knowledge of European data protection law
CIPM
Certified Information Privacy Manager - demonstrates ability to operationalise privacy programmes
You'll have a named DPO who gets to know your business. They're your DPO - not a helpdesk or a rotating cast of consultants.
Term and Review
Minimum engagement term is 12 months, renewable annually.
Privacy compliance is ongoing, not a one-off project. Twelve months gives time to establish proper processes and demonstrate value. At each renewal, we review scope and priorities to make sure the service still fits your needs.
Combining with Other Services
The DPO service works well alongside Oxford Infosec's other offerings:
vCISO - your DPO handles data protection while your vCISO handles information security more broadly. They coordinate to ensure a coherent approach - security and privacy overlap significantly, and it helps to have both working together.
ISO 27001 Implementation - if you're pursuing ISO 27001 certification, your DPO ensures the privacy elements are covered properly. Many ISO 27001 controls relate to personal data, and having a DPO in place demonstrates commitment to data protection.
For organisations with both security and privacy needs, engaging vCISO and DPO services together provides comprehensive coverage without the overhead of multiple full-time hires.
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