Under GDPR, a Data Protection Officer is a designated person (or external service) responsible for overseeing your organisation's data protection strategy and ensuring compliance. For many small businesses, the DPO role is the single most under-resourced compliance requirement — and also one of the most practically valuable.
When a DPO is legally required
GDPR Article 37 makes a DPO mandatory in three situations:
- Public authorities and bodies — government agencies, public institutions, councils
- Large-scale systematic monitoring of individuals — companies whose core activity involves tracking people's behaviour at scale (ad networks, location services, surveillance systems)
- Large-scale processing of special category data — health records, biometric data, criminal records, political opinions, religious beliefs, genetic data
Most small businesses do not meet these thresholds and are not legally required to appoint a DPO. However, many regulators and advisors recommend appointing one voluntarily, because the role protects you whether or not it's mandatory.
What a DPO actually does
A Data Protection Officer's responsibilities under GDPR Articles 38 and 39 include:
- Advisory role: Advising the business on its obligations under GDPR and other data protection laws
- Monitoring compliance: Reviewing policies, procedures, and processing activities for compliance — including staff training
- Data Protection Impact Assessments (DPIAs): Advising on and monitoring DPIAs for high-risk processing activities
- Cooperation with the regulator: Acting as the primary contact for the ICO (UK) or relevant national supervisory authority
- DSAR handling: Acting as the contact point for data subjects exercising their rights (access requests, erasure requests, objections)
- Breach notification: Supporting the breach response process and regulatory notification
The SMB problem with DPO requirements
Even if a DPO isn't mandatory, the functions they perform are. Someone in your organisation needs to: keep your privacy policy current, handle DSAR requests within 30 days, manage cookie consent records, maintain data processing agreements with suppliers, respond to the regulator if you receive a complaint, and keep up with changes in data protection law.
For a small business, none of this is a full-time job — but all of it is someone's job. When no one owns it, it doesn't get done.
The outsourced DPO — permitted under GDPR
GDPR Article 37(6) explicitly permits organisations to appoint an external DPO — a consultant, a firm, or a service. The external DPO must be accessible to staff and data subjects, have no conflicts of interest, and be able to fulfil all DPO functions. An outsourced DPO is cheaper than a full-time hire and gives you specialist expertise rather than one generalist.
How Trust Center provides the DPO function
Trust Center is built around the practical reality of how small businesses experience data protection. Rather than selling you a policy document and leaving you to manage it, Trust Center handles the ongoing obligations that a DPO would normally own:
- Privacy policy maintenance: Your privacy policy is kept up to date as laws change — you don't need to track regulatory developments yourself
- DSAR handling: Your Trust Center includes a DSAR intake form. Requests are logged, tracked against the 30-day deadline, and routed to your team with all the information needed to respond
- Cookie consent management: Cookie consent is managed and recorded — the records a DPO would need to demonstrate compliance are maintained automatically
- Regulatory horizon scanning: When laws change — new legislation, ICO guidance updates, EDPB decisions — Trust Center's content and policy templates are updated accordingly
- Contact point for data subjects: Your Trust Center page gives visitors a clear, accessible route to exercise their rights — which is a core DPO function
What Trust Center does not replace
Trust Center is a compliance platform, not a legal adviser. It does not provide legal opinions, represent you in ICO investigations, or draft bespoke data processing agreements for complex situations. For regulated sectors (healthcare, financial services, legal) or for processing activities of unusual complexity or risk, a qualified DPO or data protection lawyer should be engaged alongside Trust Center.
Getting started
Trust Center connects to your website via a single DNS record — no code installation, no developer required. Once connected, your privacy policy, DSAR form, cookie consent, and trust page are live within minutes. You've outsourced the operational DPO function to a platform built specifically to handle it.