Nordic Privacy Arena 2025 – key insights and discussion topics
Nordic Privacy Arena (NPA) is the most significant Nordic conference focusing on data protection and privacy. It is held annually
Perspectives on Outsourced Data Protection
Can the role of a Data Protection Officer (DPO) be outsourced, and what are the benefits?
“The role of a DPO can certainly be outsourced,” says GDPR specialist and outsourced Data Protection Officer Jaanaliisa Kuoppa. Surprisingly large organizations have chosen this solution. The position requires specialized expertise and continuous skills development, which few organizations have the capacity to maintain. Most companies also lack the resources to appoint a full-time expert to the role, Jaanaliisa continues.
The benefit of outsourcing lies in the fact that a dedicated expert gathers insights and solutions across different clients, which in turn effectively benefits the purchasing client organization.
When should the role of a DPO not—or should not—be outsourced? Outsourcing is not recommended when the role requires 100% commitment and intensive collaboration with the organization’s experts and management, Jaanaliisa explains. Even then, outsourcing is possible, but it may not necessarily be optimal for the client organization.
If the Work Is Not Done, Data Protection Debt Accumulates
“The DPO’s workload varies significantly depending on the industry, the size of the organization, and its geographical scope and location,” explains GDPR Tech founder, information management and technology architect Juha Sallinen.
Juha provides a concrete example: “One of our new clients had previously allocated only four hours per month of one person’s time for data protection work. This led to a data protection debt, because in that time it is not possible to provide guidance, training, self-development, let alone monitor changes in privacy interpretations, and so on.”
The client initially tackled the debt with 16 hours of monthly effort. Since then, the workload has been adjusted to eight hours per month, supplemented by additional tasks as needed.
In an international organization, simply monitoring state-specific privacy changes in the United States alone consumes significant work hours. A functional structure in international organizations often seems to be a “Global Head of Privacy” supported by an operational team, Juha notes. The DPO’s role is to guide and supervise, which often requires a determined, project manager–like approach.
Data Protection Debt Can Be Reduced Through Determined Project Work
GDPR Tech’s Technical Project Manager, Mervi Hongisto, shares her perspective:
“It is essential to define how much data protection work will be carried out proactively and in a controlled manner during regular office hours. At the same time, it must be assessed what risks the organization is willing to accept regarding tasks left undone.”
Even a small amount of systematic neglect is inadequate for risk management and therefore not advisable.
“Good project management provides concrete tools and visibility into the key priorities of data protection work,” Mervi continues. An outsourced project manager can at best provide the client with a prioritization overview that is aligned with the client’s other assignments. At the same time, effective implementation is ensured, which also builds the client’s own expertise.
Responsibility of the Service Provider and the Client
“There is a known case where a single consultant acts as the DPO for as many as 600 organizations,” Juha Sallinen points out. This raises a critical question about the adequacy of resources. The client bears the responsibility to ensure that the purchased service truly meets the requirements of data protection work. The provider, in turn, must be able to demonstrate that the resources and expertise are sufficient to serve such a wide client base. This highlights the importance of quality and accountability in data protection practices.
Ideally, an organization itself should have enough knowledge to decide whether it wants—or is able—to outsource the DPO role.
At GDPR Tech, we have a structured, cost-effective, and easily customizable approach to delivering the service.
Responsibility itself cannot be outsourced, even if many other things can.
Considering Outsourcing Your Data Protection Work?
DPOaaS (Data Protection Officer as a Service) is a safe and cost-effective solution when you need an expert to help your company meet current, legally mandated data protection obligations—without hiring a full-time employee.
Get in touch also if you need a temporary substitute, a backup person for your DPO work, or a sparring partner to assess the state of your data protection!
Experts Featured in the Article:
Jaanaliisa Kuoppa – GDPR Specialist, Outsourced Data Protection Officer, part of the DPO Team
Juha Sallinen – Entrepreneur, Information Management and Technology Architect, Outsourced Data Protection Officer, part of the DPO Team
Mervi Hongisto – Technical Project Manager, Outsourced Data Protection Officer, part of the DPO Team
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