Outsource Your DPO: Cut Compliance Costs by 70%

Last Updated on October 20, 2025 by Narendra Sahoo

The General Data Protection Regulation (GDPR) and the UK’s Data Protection Act 2018 (DPA 18) have transformed how businesses must handle personal data. With fines of up to €20 million or 4% of global annual turnover for non-compliance, organisations cannot afford to take data protection lightly. The law‑firm DLA Piper reports that by January 2025 the total fines across Europe since GDPR came into force stood at €5.88 billion.

source: DLA Piper GDPR Data Breach Report 2025

UK‑specific numbers are harder to pin down in the same way, in part because of differences in reporting and because the ICO has been more conservative with large fines compared with some EU regulators.

Here what we know:

• In 2024, the UK imposed 18 fines, totalling about £2.7 million.
• The average ICO fine in 2024 was £153,722.
• In 2024/25 the ICO received 12,412 personal data breach reports

One of the most significant requirements under GDPR is the appointment of a Data Protection Officer (DPO) in certain circumstances. However, many businesses struggle with the practicalities: recruiting, training, and retaining a qualified DPO can be costly and time-consuming.

That’s where outsourcing to experts like Compliance Direct Solutions becomes not just a compliance choice—but a strategic and cost-effective business decision.

What Does GDPR Require from Businesses?

In short to meet GDPR and DPA 18 obligations, businesses must:

• Maintain records of processing activities
• Identify & demonstrate lawful bases for processing personal data
• Implement technical and organisational measures
• Conduct Data Protection Impact Assessments (DPIAs)
• Ensure transparency
• Report data breaches
• Appoint a DPO (Data Protection Officer)

Let’s take a closer look at some of the key challenges:

Maintaining Records of Processing Activities (Article 30 GDPR)

Challenge:

• Complexity of operations: Small, Medium & Large organisations often process data across multiple departments, systems, and countries. Mapping out all processing activities accurately is resource intensive.
• Ongoing maintenance: These records must be kept up to date. Any new processing activity or change in purpose must be documented.
• Accountability pressure: Regulators can request this documentation at any time to assess compliance.

Maintenance is often overlooked, documents are not appropriately updated, breaches or customer complaints happen & the regulator comes down to investigate. The cost associated with being reactive are far greater than proactively taking steps to ensure you are maintaining your records of data processing.

Identifying Lawful Bases for Processing Personal Data & Demonstrating Compliance

Challenge:

• Legal nuance: Choosing the correct lawful basis (e.g., consent, contract, legitimate interests) requires legal understanding. Mistakes can invalidate the processing.
• Documentation burden: Organisations must be able to demonstrate their reasoning (e.g., via legitimate interest assessments), especially when relying on “legitimate interests.”
• Granular consent requirements: If using consent, it must be freely given, specific, informed, and unambiguous—difficult to ensure in online platforms or indirect data collection.

Identifying a lawful basis for processing personal data is not just a legal formality—it’s a foundational requirement. However, the challenge lies in the complex interplay of legal interpretation, operational execution, and evidentiary accountability. This challenge demands cross-functional coordination between legal, compliance, IT, and product teams, and even then, the balance between operational efficiency and regulatory compliance is difficult to strike.

Appointing a Data Protection Officer (DPO)

Challenge:

• Determining necessity: Businesses often struggle to determine whether their processing meets the threshold for mandatory DPO appointment.
• Finding qualified personnel: A DPO must have expert knowledge of data protection law and practices, which are in high demand and short supply.
• Independence and autonomy: The DPO must operate independently and report to the highest level of management—something that can conflict with internal business hierarchies or priorities.

An external DPO service brings immediate access to specialised expertise, ensures regulatory compliance, and provides the independence required by law—without disrupting internal structures or incurring the cost of a full-time hire. It also allows for scalability, adapting as the organisation’s data processing activities evolve. In short, for many businesses, outsourcing the DPO role is not just compliant—it’s strategically and operationally smarter.

The Role of the Data Protection Officer (DPO)

A DPO acts as the linchpin between your organisation, regulators, and individuals whose data you process. Their responsibilities include:

• Monitoring GDPR compliance across the organisation.
• Advising on DPIAs and high-risk processing.
• Acting as the main point of contact for the ICO (Information Commissioner’s Office).
• Raising staff awareness through training and policy guidance.
• Advising senior management on emerging risks and regulatory changes.

Why Outsourcing the DPO Role Makes Business Sense

Cost-Effectiveness:

Hiring an in-house DPO is expensive. Salaries for experienced professionals often range from £60,000 to £100,000+ per year—before factoring in recruitment fees, ongoing training, pension contributions, and employee benefits. By contrast, outsourcing to Compliance Direct Solutions offers flexible packages, often starting at a fraction of the cost. Businesses gain access to a team of experts without the overheads of a full-time hire.

Instant Expertise:

A newly appointed in-house DPO may need months of training to fully understand your sector and GDPR intricacies as well as embedding within business operations. With outsourcing, you immediately gain access to a team of seasoned data protection professionals who already have experience working across industries. We also take the time to onboard each customer to fully integrate within your business and team. As we manage this process, we ensure that the integration is seamless and does not take away from your business-as-usual activities.

Flexibility and Scalability:

Not every organisation needs a full-time, permanent Data Protection Officer — but every organisation needs the right support at the right time. Having access to flexible, tailored DPO services designed to meet your specific requirements is a key benefit to the outsourced model — whether you’re looking for occasional advice, interim support, or a fully outsourced named DPO. Our DPO support services are built to scale with your business and evolve as your data protection needs change.

We can act as your:

• Interim DPO – Ideal for bridging gaps during recruitment, managing short-term projects, or supporting busy periods like audits or product launches.
• Advisory DPO – Providing on-demand expertise to support your internal team with complex compliance queries or regulatory updates.
• Outsourced Named DPO – A complete end-to-end solution where we take on the formal responsibilities of the DPO, ensuring independence, continuity, and full compliance with legal requirements.

With a team like ours you get expertise on demand, cost-effective support, and the peace of mind that your data protection obligations are in safe hands — all without the overhead of hiring internally.

Reduced Risk of Conflicts of Interest:

Under GDPR, a DPO must operate independently and without conflicts. For example, your Head of IT or HR cannot double up as DPO because they make decisions about data processing. Outsourcing eliminates this risk entirely, ensuring compliance with Article 38 GDPR.

In practice, this creates a major challenge: many of the roles with the necessary knowledge of data processing—such as Heads of IT, Legal, Compliance, Security, or HR—are also the ones actively making decisions about data strategy and implementation. If any of these individuals were appointed as DPO, it would violate GDPR requirements, exposing the organisation to compliance risks and potential enforcement action.

Outsourcing the DPO role eliminates this conflict entirely. An external DPO is not embedded within your operational hierarchy and has no vested interest in internal decision-making. This ensures they can act independently, offer unbiased advice, and carry out their oversight duties in line with GDPR obligations.

The True Cost of DPO Recruitment vs Outsourcing:

Outsourcing saves businesses an average of 70–80% per year, while still delivering full compliance assurance.

Frequently Asked Questions (FAQ)

Does my business legally need a DPO?

You must appoint a DPO if your organisation:

• Processes large amounts of personal data systematically (e.g., tracking behaviour online).
• Handles sensitive categories of data (health, biometrics, criminal records).
• Is a public authority or body.

Even if not legally required, many businesses choose to appoint a DPO voluntarily to demonstrate accountability.

Can an employee double as the DPO?

Only if there is no conflict of interest. For example, senior managers who influence data processing decisions (IT, HR, Marketing) cannot serve as DPOs. They candidate also need the relevant knowledge, experience & qualifications to fulfil the role.

What happens if I don’t appoint a DPO when required?

The ICO can issue fines and enforcement action. Beyond regulatory risk, failing to appoint a DPO leaves your business exposed to data breaches and reputational damage.

Why outsource instead of training someone internally?

Internal staff may lack the specialist knowledge required to keep up with evolving data protection law. Outsourcing ensures access to a team of experts at a predictable, lower cost. The time frames are also significantly reduced, from intro call to delivery we can kick start a project immediately ensuring instant impact.

How does Compliance Direct Solutions support businesses as an outsourced DPO?

We provide:

• Ongoing compliance monitoring and reporting.
• Delivery of all key complaince tasks and frameworks
• Advice on DPIAs and lawful processing.
• Breach response and liaison with the ICO.
• Regular staff training and awareness programmes.
• Tailored compliance frameworks to fit your sector.

GDPR compliance is not a one-off task—it’s an ongoing responsibility. Businesses that ignore or under-resource data protection expose themselves to financial penalties and reputational harm.

Outsourcing the DPO role to experts like Compliance Direct Solutions is the most cost-effective, flexible, and reliable way to stay compliant. Whether you need interim support or a permanent outsourced DPO, we can deliver peace of mind and allow you to focus on what matters most, growing your business.

Ready to reduce your risk and free up your internal resources?

To schedule a no-obligation consultation and discover how outsourcing your GDPR compliance can transform your risk posture and operational efficiency.

Contact Us Today.

Narendra Sahoo

Narendra Sahoo (PCI QPA, PCI QSA, PCI SSF ASSESSOR, CISSP, CISA, CRISC, 27001 LA) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.

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