GDPR is Not Going Away.
And You Are Not Sure You Are Compliant
Data protection regulation is tightening everywhere. Fines for breaches run into millions. You need senior expertise making sure your data handling is compliant, your risk is managed, and your team knows what they are doing. A Fractional Data Protection Officer gives you exactly that, without hiring full-time.
Data Protection Expertise. Always There.
A Fractional Data Protection Officer, sometimes engaged as a Data Controller, is an outsourced senior specialist who manages your organisation's data protection obligations on a part-time basis. They make sure every part of your data processing is compliant with the General Data Protection Regulation and the wider Irish and European data protection framework, while keeping the cost in proportion to the size of your business.
Most Irish businesses discover they have data protection gaps only after something goes wrong. A fractional Data Protection Officer prevents that. They map where personal data flows through your business, assess your risk, design compliant processes, train your team, oversee breach response, and act as the named point of contact for the Data Protection Commission and for the people whose data you hold.
Unlike full-time employment, the role scales with your needs. You get specialist guidance and a senior signature on your privacy programme when you need it, at a fraction of the cost of a permanent hire. Ideal for organisations that take compliance seriously and want a proportionate, expert led solution.
Start the ConversationSenior data protection leadership at a fraction of the cost of a permanent hire, with the depth, independence and regulatory experience your business needs.
What your Data Protection Officer actually delivers
The role flexes to the business, but most engagements cover four broad areas of work. Some weeks lean towards policy and assessment work, others on training, breach response or regulator engagement. The constant is having a senior, independent data protection mind inside the business on the days you need them.
- Records of Processing Activities (Article 30) and data mapping
- Privacy notices, cookie policies and consent design
- Internal data protection policy and staff handbook updates
- Data sharing, retention and deletion schedules
- GDPR gap analysis and annual compliance audits
- Data Protection Impact Assessments (DPIAs) for new projects
- Legitimate Interest Assessments and lawful basis reviews
- Vendor and processor due diligence, including international transfers
- Privacy by design embedded into product and process
- Incident response plans and 72-hour breach notification readiness
- Subject Access Request handling and rights of the data subject
- Liaison with the Data Protection Commission on queries and complaints
- Board level reporting on data protection risk and posture
- Staff awareness training tailored to your sector and roles
- Coaching for internal data champions and process owners
- Standing item at leadership meetings on regulatory change
Do you need a Data Protection Officer?
Under Article 37 of the GDPR, a Data Protection Officer is a legal requirement in three specific situations. Even when it is not strictly mandated, appointing a DPO is widely regarded as best practice, and the Data Protection Commission looks favourably on organisations that demonstrate this level of accountability. The fractional model is a proportionate way to meet either bar.
Public sector organisations, local authorities, education bodies and most state funded entities must designate a DPO, regardless of their size or the volume of data they handle.
If your core activities involve regular and systematic monitoring of individuals at scale, such as behavioural tracking, profiling, CCTV networks or location data, a DPO is required.
Processing health, biometric, genetic, criminal, religious or other special category data at scale triggers the mandatory appointment of a Data Protection Officer.
Even outside the legal triggers, appointing a DPO demonstrates accountability under Article 5(2), reassures customers and partners, and gives the board independent assurance that data protection is being managed properly.
Increasingly, enterprise customers, public tenders and insurance providers ask whether you have a named Data Protection Officer in place before they will sign or renew.
If you transfer personal data outside the EEA, rely on Standard Contractual Clauses, or operate across multiple jurisdictions, having a DPO in place gives you the structured oversight these arrangements demand.
Signs it is time to bring in a Fractional DPO
Most organisations do not wake up one morning and decide they need a Data Protection Officer. The need builds over time, usually showing up as a few familiar signals. If two or three of these feel close to home, it is probably the right moment to have a conversation.
You hold more customer, employee or service user data than ever before, across more systems, and the leadership team wants confidence that it is being handled properly.
An incident, a lost device, a misdirected email or a supplier issue has made everyone aware that the current set up is not robust enough for the level of risk you carry.
You are receiving more data subject requests, complaints or queries, and you need someone senior to handle them within the statutory timeframes and to a high standard.
A new platform, app, AI feature or data sharing arrangement is in the pipeline, and you want a Data Protection Impact Assessment done properly before it goes live.
A large customer, public sector tender or insurance renewal now asks for evidence of a named DPO, a current ROPA and a documented data protection programme.
You are processing data across borders, opening into new EU markets or working with international processors, and you need a coherent governance layer across all of it.
Data protection experience across regulated industries
Our Data Protection Officer network has built privacy programmes in the sectors where the regulatory burden is highest. Each DPO brings practical understanding of the data flows, supervisory expectations and sector specific guidance that shapes compliance in their industry.
Patient records, clinical trial data, medical devices and digital health platforms. Special category data, HSE engagement and research ethics, handled by DPOs who know the sector.
Customer onboarding, KYC and AML records, payments data and lending platforms. Aligned with Central Bank expectations, DORA and the wider regulatory framework.
Local authorities, education bodies, charities and state funded organisations where appointing a DPO is mandatory. Independent, conflict free and proportionate support.
Product privacy by design, AI feature reviews, processor agreements and international transfers for software, platform and digital businesses scaling across Europe.
Loyalty programmes, marketing consent, CCTV networks and customer profiling for retail, ecommerce, hospitality and consumer brands across Ireland.
Student and client records, online learning platforms, HR data and case files for education providers, law firms, consultancies and advisory businesses.
Three steps to senior data protection leadership
From the first conversation to a Data Protection Officer inside the business, typically inside a single week.
A focused conversation. You tell us where you are, where you want to be, and the data protection capability gap that is holding the business back.
We hand-pick two or three vetted Data Protection Officers from our network with direct experience in your sector, your data risk profile and your growth stage.
Your DPO embeds with the team on a flexible schedule, typically one to three days a week, delivering tangible compliance outcomes from week one.
From first call to full compliance in three steps
We understand what data you process, how it flows through the business, where it is stored, who has access, and where the compliance gaps sit. A clear, prioritised picture of your data protection risk.
Your fractional Data Protection Officer designs a tailored roadmap. What needs to change, in what order and by when. Policy, process and training, sequenced to be realistic, doable and embedded into your operations.
Regular check-ins, board updates, training refreshes, DPIAs on new initiatives and regulatory guidance. You stay compliant as the business evolves and the regulatory landscape changes around you.
Questions leaders ask before they start
Does my organisation need a Data Protection Officer under GDPR?
A DPO is mandatory under Article 37 of the GDPR if you are a public authority or body, if your core activities involve large scale systematic monitoring of individuals, or if you process special categories of data at scale. Outside those legal triggers, many organisations still choose to appoint one as a matter of best practice and accountability. We can help you work through whether you are in scope during the discovery call.
What is the difference between a Data Protection Officer and a Data Controller?
The Data Controller is the organisation, or person, that decides why and how personal data is processed. The Data Protection Officer is an independent specialist who advises the Controller on how to meet its GDPR obligations, monitors compliance and acts as the point of contact for data subjects and the Data Protection Commission. Our fractional engagements can provide either the DPO role, or Data Controller advisory support, depending on what your organisation needs.
How much does a fractional Data Protection Officer cost?
Engagements are scoped around the days per month your organisation actually needs. The headline point is that you access the same calibre of senior data protection expertise as a permanent appointment at a fraction of the cost of a full-time hire, with no recruitment fees and the flexibility to scale the engagement up or down as your data processing changes. We talk through the right shape of engagement during the discovery call.
Can a Fractional DPO be the named contact on our public privacy notices?
Yes. Where the role is appointed under Article 37, your Fractional DPO is named in your privacy notices, registered with the Data Protection Commission, and acts as the formal point of contact for data subjects and the regulator. They are independent of the operational lines of the business, which is a core requirement of the role.
How quickly can a Fractional DPO be in place?
Most engagements move from first call to a named DPO embedded in the business within a week. After the discovery call, we hand-pick two or three vetted candidates from our network, you choose the right fit, and the engagement starts with a clear mandate and prioritised first 90 days plan.
Will the DPO work with our existing IT, legal and HR teams?
Yes. A fractional Data Protection Officer is designed to slot in alongside your existing functions. They partner with IT and security on technical controls, with legal on contracts and processor agreements, and with HR on staff training, employee data and incident response. The DPO brings the privacy specific lens that ties it all together.
What happens if we have a data breach?
Your Fractional DPO leads the response. They help contain the incident, assess the risk to data subjects, prepare and submit the 72-hour notification to the Data Protection Commission where required, manage communications to affected individuals, and lead the post-incident review so that the same issue does not recur.
Ready to Find Your DPO?
Tell us about your data handling and compliance concerns. We will be back in touch within 48 hours to set up a discovery call.