Choosing your DPO:Full-Time, Service or Consult?
I've noticed many SMEs running LinkedIn ads for DPOs, who are recruiting full-time employees. And it’s disappointing to see how often other options are overlooked.
Which DPO Option and Benefits Suit You Best?
I think it’s important to consider all the available options before making a decision. Yes, you could employ a Full-Time DPO for your business. Or, for example, you could contract with DPO specialists to provide DPO as a service. Or appoint an internal ‘non-specialist’ and support them with an external data protection consultancy or consultant.
I’ve listed below some of the benefits from these options, so that the next time you need to find a DPO, you have information to help you make an informed decision about what type of DPO you actually need, and what solution might fit you best.
1. Cost
As with any new employee, hiring a highly qualified full-time DPO involves significant costs, especially in salary and benefits. Outsourcing the DPO role, or appointing an internal non-specialist with consultant support means you only pay for the DPO services and time you use. You don’t need to consider staff benefits, holiday, sickness, appraisals, or, if you’ve employed the wrong person, the time, cost and expense involved in letting them go. Nor do you need to be concerned about FTE overheads like office space, equipment or other resources.
2. Expertise
Internal DPOs may struggle with budget constraints and limited resources. Outsourcing can provide a more cost-effective solution with access to necessary resources as needed. An outsourced DPO service can provide more or less support month by month, depending on your needs. You can choose how much time you need, and, in any case the time required can be flexible. You can ramp it up or down depending on whether you have a large project, or simply need ongoing maintenance. It also means that if you only need an interim DPO, you can appoint your consultant temporarily with no need for long term commitment.
3. Flexibility / Scalability
Top quality DPOs (whether FTE or outsourced) are experts in data protection law regulations. But perhaps the biggest advantage to using the DPO-as-a-Service or consultancy option is that those DPOs will have gained considerable and diverse experience from working in many different industry sectors. They see many and varied solutions to common data protection issues from the numerous clients with whom they work. And vitally, within a team of DPOs in a consultancy, they will always be learning from each other, considering solutions based on the shared knowledge of the whole team. And that shared knowledge becomes your company’s shared knowledge.
4. Unbiased Approach
An outsourced DPO or consultant has the advantage of being independent and unconflicted, and is able to consider your issues with fresh eyes and no bias. This means that they can conduct unbiased audits and assessments of your data protection practices and help you implement any remedial actions.
5. Internal Challenges
Full-time DPOs often face challenges such as lack of support from key stakeholders and cooperation within the organisation. Although fully engaged with the client and its goals, outsourced DPOs can navigate these challenges more effectively due to the independence they hold through their external position.
Conclusion
The traditional route of hiring a full-time employee may be perfect for many companies. But it’s clearly not the only solution. So when you next need to appoint a DPO, you could consider being more inclusive by stating that full-time employees and DPO-as-a-Service Providers or consultants are welcome to apply.
That way you can be sure that you don’t miss out by excluding the right person by default. And of course, you can review and interview applicants as normal and make your own decision about which individual or option fits your needs best.
Data Compliant International
If you are looking for a DPO or supportive consultant, Data Compliant International provides DPO-as-a-Service, and data protection / privacy consultants to a wide range of business sectors. If you’d like to know more about how we help our clients, please take a look here. If you would like help or assistance with any of your data protection obligations, please email dc@datacompliant.co.uk or call 01787 277742.
Data Compliant International
International data protection consultants and DPOs.
22 Friars Street, Sudbury, Suffolk, CO10 2AA
Email: dc@datacompliant.co.uk
Tel No.: +44 (0) 1787 277 742
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